View László Fülöp’s profile on LinkedIn, the world’s largest professional community. László has 10 jobs listed on their profile. See the complete profile on LinkedIn and discover László’s connections and jobs at similar companies. to a "reorganization," the latter being viewed as merely a change in the form of doing business rather than a termination of the busi-ness.4 This comment explores the area shown by recent develop-1 See MacLean, Problems of Reincorporation and Related Proposals of the Sub-chapter C Advisory Group, 18 TAx L. REv.
1) The control requirement is best defined by Section 368(c), which requires ownership of 80 percent of the total combined voting power and 80 percent of the total number of shares of all other classes of stock, including nonvoting preferred stock. Internal Revenue Code § 368(a)(1)(A) In an A reorganization, the target corporation ("Target") merges into the acquiring corporation ("Acquiring") with the former Target shareholders receiving the merger consideration in exchange for their Target stock.. A Reorganization Diagram. Post-Transaction Structure. To qualify as a reorganization, a merger must constitute a "statutory merger or ...
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