Question
Complete the Tax Treatment column on the following chart, indicating whether the transaction qualifies as an A, B, or C reorg. If the transaction does
Complete the Tax Treatment column on the following chart, indicating whether the transaction qualifies as an A, B, or C reorg. If the transaction does not qualify as an A, B, or C reorg, then put Taxable in the Tax Treatment column. Each category (A, B, C, etc.) might be used more than once; and not all categories may appear. P and T are both C corporations. No cites or explanations are required; just complete the chart. Transaction Tax Treatment: A, B, C, or Taxable
A. P makes a tender offer directly to the shareholders of T to acquire the T stock in an exchange of one share of P voting common stock for each share of T stock. All of the T shareholders accept the tender offer.
B. Pursuant to a purchase and sale agreement, T transfers all of its assets to P for 900 shares of voting common stock of P worth $900,000 and $100,000 of cash. P assumes all of Ts liabilities ($200,000) in the transaction. T liquidates and distributes the P stock and cash to its shareholders.
C. P makes a tender offer directly to the shareholders of T to acquire the T stock in an exchange of one share of P voting common stock worth $95 and $95 of cash for each share of T stock. All of the T shareholders accept the tender offer.
D. Pursuant to a state law statute governing mergers, T is merged into P. The T shareholders surrender their T stock in exchange for P voting stock.
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