Suppose you are a CPA, and you have a corporate client that has been operating for several years. The company is considering expansion through reorganizations. The company currently has two subsidiaries acquired through Type B reorganizations. The client has asked you for tax advice on the benefit of a Type A, C, or D reorganization over a Type B reorganization. Additional facts regarding the issues are reflected below.

• The company currently files a consolidated income tax return with the two subsidiaries acquired through a Type B reorganization.
• ABC Corporation, a subsidiary targeted by the client for takeover, has substantial net operating losses.
• XYZ Corporation and BB Corporation will be acquired as subsidiaries in the next six months.

1. Compare the long-term tax benefits and advantages of each type of reorganization and recommend the type of reorganization that will be most beneficial to the client.
2. Suggest the type of reorganization the client should use for the ABC Corporation based on your research.