Question
Can someone please help me with Advanced Federal Income Tax 7. How does the IRS interpret the substantially all asset requirement for a Type C
Can someone please help me with Advanced Federal Income Tax
7. How does the IRS interpret the "substantially all" asset requirement for a Type C reorganization?
A. At least 90% of the FMV of the gross assets and 90% of the FMV of the target corporation's net assets be acquired.
B. At least 70% of the FMV of the gross assets and 90% of the FMV of the target corporation's net assets be acquired.
C. The IRS interprets "substantially all" for a Type C reorganization by state law and looking into the corporation's charter and bylaws.
D. None of the above.
8. Some acquisitive transactions may be characterized as either a Type C or a Type D reorganization. Which reorganization provision controls if the two types overlap?
A. When an acquisition qualifies as either a Type C or a Type D reorganization, it is considered to be a Type D reorganization.
B. When an acquisition qualifies as either a Type C or a Type D reorganization, it is considered to be a Type C reorganization.
C. When an acquisition qualifies as either a Type C or a Type D reorganization, it is considered to be a Type B reorganization.
D. When an acquisition qualifies as either a Type C or a Type D reorganization, it is considered to be a Type A reorganization.
9. What is the difference between an acquisitive Type C reorganization and an acquisitive Type D reorganization?
A. Type C reorganizations do not require all of the assets of the target corporation to be acquired. However with Type D reorganizations one of the requirements is that substantially all of the assets of the target corporation be acquired.
B. With Type C reorganizations, the target corporation's shareholders usually do not control the acquiring corporation after the acquisition. However with Type D reorganizations the target corporation or one of its shareholders must control the acquiring corporation immediately after the asset transfer.
C. With Type C reorganizations, the target corporation or one of its shareholders must control the acquiring corporation immediately after the asset transfer. However, with Type D reorganizations the target corporation's shareholders usually do not control the acquiring corporation after the acquisition.
D. Both A and C are correct.
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