Possible PPP Legislation & 1099-B

“B” Reorganization Type “B” involves the acquisition of stock of one corporation by another, and the target corporation becomes a subsidiary of the acquiring, as a result. Requirements of “B” Reorganization 1) The acquisition must be one of a series of acquisitions that are part of an overall plan to acquire the requisite control. 2)…

“C” Reorganization The target corporation must liquidate as part of the plan of reorganization unless the IRS waives this requirement.’ As a result, the shareholders of the target corporation become shareholders in the acquiring corporation. In determining the tax consequences to the liquidating target, the reorganization provisions govern-not the liquidation rules of §§ 336 and…

“D” reorganization: “Spin-off” and “Split-off”   acquisitive d reorganization “D” Reorganization Explanation: * Corporate T contains the assets of former corporation A and of T. * Corporation A goes out of existence Corporation A’s shareholder’s control Corporation T. Requirements for Divisive “D” d reorganization requirements imposed by IRC §355 * Distribution of Control -by the…

“E” Reorganization The “E” reorganization is defined as a re-capitalization – the exchanges of stock and securities for new stock and/or securities by the corporation’s shareholders. It involves only one corporation and the re-configuration of its capital structure. Stock for stock Differences in the voting rights, dividend rates, and preference on liquidation are ignored. Bonds…