Question 1

The "Type F" is the mere change in ____________________, ____________________, or _________________________.
or

Accepted Answer

The answer of The "Type F" is the mere change...

Question 2

The ____________________ doctrine ensures that the acquiring corporation cannot immediately sell the target corporation assets it receives in the reorganization. The ____________________ doctrine also prevents transactions that appear to be sales. However, these are sales by the target shareholders to the acquiring corporation.

Accepted Answer

The answer of The ____________________ doctrine ensures that the acquiring...

Question 3

In a ____________________ reorganization the creditors rather than the shareholders are considered when testing the continuity of ____________________ doctrine.

Accepted Answer

The answer of In a ____________________ reorganization the creditors rather...

Question 4

An equity structure shift occurs when a(n) ____________________ causes an ownership change of ____________________ percentage-points for any common shareholders owning at least 5%. A sale or issuance of stock can cause a(n) ____________________ to take place.

Accepted Answer

The answer of An equity structure shift occurs when a(n)...

Question 5

The ____________________ doctrine treats several transactions as if they were one transaction when they are all integrated. The ____________________ doctrine ensures that the restructuring has a purpose beyond tax avoidance or evasion.

Accepted Answer

The answer of The ____________________ doctrine treats several transactions as...

Question 6

The acquisitive "Type D" reorganization differs from other restructurings in that the entity that transfers its assets is the ____________________ corporation rather than the ____________________ corporation.

Accepted Answer

The answer of The acquisitive "Type D" reorganization differs from...

Question 7

Match the following items with the statements below. Terms may be used more than once.

Accepted Answer

The answer of Match the following items with the statements...

Question 8

Liabilities are problematic only in the ____________________ reorganization when the ____________________ corporation transfers other property as well as stock to the target.

Accepted Answer

The answer of Liabilities are problematic only in the ____________________...

Question 9

A "Type A" reorganization that is the union of two or more corporations with one retaining its existence is called a ____________________. A ____________________ is when a new corporation is created to take the place of two or more corporations.

Accepted Answer

The answer of A "Type A" reorganization that is the...

Question 10

To qualify as a tax-free reorganization, a corporate restructuring must meet not only the specific requirements of § 368 but also four general requirements. These four requirements are: ____________________, ____________________, ____________________, and _________________________. In addition, the ____________________ doctrine should not apply to the reorganization.
or

Accepted Answer

The answer of To qualify as a tax-free reorganization, a...

Question 11

A ____________________ reorganization is a recapitalization of a single corporation.

Accepted Answer

The answer of A ____________________ reorganization is a recapitalization of...

Question 12

One of the tenets of the U.S. tax policy is to ____________________ business development. As an extension of this concept, corporate restructurings are given ____________________ treatment.

Accepted Answer

The answer of One of the tenets of the U.S....

Question 13

If stockholders of the corporations involved in a tax-free reorganization receive ____________________ in addition to stock, they may recognize gain. The character of the gain is either ____________________ or ____________________.
or
or
or

Accepted Answer

The answer of If stockholders of the corporations involved in...

Question 14

The tax treatment of the parties involved in a tax-free reorganization almost exactly parallels the treatment under the ____________________ provisions. When boot is received, ____________________ may be recognized but ____________________ is not recognized.

Accepted Answer

The answer of The tax treatment of the parties involved...

Question 15

In a ____________________ divisive reorganization the original distributing corporation disappears. In a ____________________ divisive reorganization the shareholders do not give up any of their original corporation stock to receive stock in the new corporation, whereas in a ____________________ stock in the original is exchanged for stock in the new corporation.

Accepted Answer

The answer of In a ____________________ divisive reorganization the original...

Question 16

The ____________________ provides a restriction on the amount of tax attributes that can be carried over from the target to the acquiring corporation after an ownership shift occurs.

Accepted Answer

The answer of The ____________________ provides a restriction on the...

Question 17

The acquiring corporation in a "Type G" reorganization must reduce the tax attributes carried over to it to the extent of the ____________________ relief.

Accepted Answer

The answer of The acquiring corporation in a "Type G"...

Question 18

The "Type C" reorganization requires that at least ____________________ percent of the value of the target's assets be acquired with ____________________ stock.

Accepted Answer

The answer of The "Type C" reorganization requires that at...

Question 19

The yearly § 382 limitation is computed by multiplying the ____________________ of the loss corporation's stock on the ____________________ date by the ____________________. For the ____________________, the § 382 limitation must be multiplied by the fraction equal to the number of days remaining in the year divided by days in the year.

Accepted Answer

The answer of The yearly § 382 limitation is computed...

Question 20

Since the ____________________ reorganization precludes the use of boot, gain is not recognized in this type of reorganization. In this reorganization, a ____________________ relationship between the acquiring and target corporations is created.

Accepted Answer

The answer of Since the ____________________ reorganization precludes the use...

Quiz 7: Corporations: Reorganizations

The "Type F" is the mere change in , , or _____. or

The doctrine ensures that the acquiring corporation cannot immediately sell the target corporation assets it receives in the reorganization. The doctrine also prevents transactions that appear to be sales. However, these are sales by the target shareholders to the acquiring corporation.

In a reorganization the creditors rather than the shareholders are considered when testing the continuity of doctrine.

An equity structure shift occurs when a(n) causes an ownership change of percentage-points for any common shareholders owning at least 5%. A sale or issuance of stock can cause a(n) to take place.

The doctrine treats several transactions as if they were one transaction when they are all integrated. The doctrine ensures that the restructuring has a purpose beyond tax avoidance or evasion.

The acquisitive "Type D" reorganization differs from other restructurings in that the entity that transfers its assets is the corporation rather than the corporation.

Match the following items with the statements below. Terms may be used more than once.

Liabilities are problematic only in the reorganization when the corporation transfers other property as well as stock to the target.

A "Type A" reorganization that is the union of two or more corporations with one retaining its existence is called a . A is when a new corporation is created to take the place of two or more corporations.

To qualify as a tax-free reorganization, a corporate restructuring must meet not only the specific requirements of § 368 but also four general requirements. These four requirements are: ________, , , and _. In addition, the ________ doctrine should not apply to the reorganization. or

A ____________________ reorganization is a recapitalization of a single corporation.

One of the tenets of the U.S. tax policy is to business development. As an extension of this concept, corporate restructurings are given treatment.

If stockholders of the corporations involved in a tax-free reorganization receive in addition to stock, they may recognize gain. The character of the gain is either or . or or or

The tax treatment of the parties involved in a tax-free reorganization almost exactly parallels the treatment under the provisions. When boot is received, may be recognized but is not recognized.

The ____________________ provides a restriction on the amount of tax attributes that can be carried over from the target to the acquiring corporation after an ownership shift occurs.

The acquiring corporation in a "Type G" reorganization must reduce the tax attributes carried over to it to the extent of the ____________________ relief.

The "Type C" reorganization requires that at least percent of the value of the target's assets be acquired with stock.

The yearly § 382 limitation is computed by multiplying the of the loss corporation's stock on the date by the . For the , the § 382 limitation must be multiplied by the fraction equal to the number of days remaining in the year divided by days in the year.

Since the reorganization precludes the use of boot, gain is not recognized in this type of reorganization. In this reorganization, a relationship between the acquiring and target corporations is created.

Quiz 7: Corporations: Reorganizations

The "Type F" is the mere change in ____________________, ____________________, or _________________________. or

In a ____________________ reorganization the creditors rather than the shareholders are considered when testing the continuity of ____________________ doctrine.

An equity structure shift occurs when a(n) ____________________ causes an ownership change of ____________________ percentage-points for any common shareholders owning at least 5%. A sale or issuance of stock can cause a(n) ____________________ to take place.

The ____________________ doctrine treats several transactions as if they were one transaction when they are all integrated. The ____________________ doctrine ensures that the restructuring has a purpose beyond tax avoidance or evasion.

The acquisitive "Type D" reorganization differs from other restructurings in that the entity that transfers its assets is the ____________________ corporation rather than the ____________________ corporation.

Match the following items with the statements below. Terms may be used more than once.

Liabilities are problematic only in the ____________________ reorganization when the ____________________ corporation transfers other property as well as stock to the target.

A "Type A" reorganization that is the union of two or more corporations with one retaining its existence is called a ____________________. A ____________________ is when a new corporation is created to take the place of two or more corporations.

A ____________________ reorganization is a recapitalization of a single corporation.

One of the tenets of the U.S. tax policy is to ____________________ business development. As an extension of this concept, corporate restructurings are given ____________________ treatment.

If stockholders of the corporations involved in a tax-free reorganization receive ____________________ in addition to stock, they may recognize gain. The character of the gain is either ____________________ or ____________________. or or or

The tax treatment of the parties involved in a tax-free reorganization almost exactly parallels the treatment under the ____________________ provisions. When boot is received, ____________________ may be recognized but ____________________ is not recognized.

The ____________________ provides a restriction on the amount of tax attributes that can be carried over from the target to the acquiring corporation after an ownership shift occurs.

The acquiring corporation in a "Type G" reorganization must reduce the tax attributes carried over to it to the extent of the ____________________ relief.

The "Type C" reorganization requires that at least ____________________ percent of the value of the target's assets be acquired with ____________________ stock.

Since the ____________________ reorganization precludes the use of boot, gain is not recognized in this type of reorganization. In this reorganization, a ____________________ relationship between the acquiring and target corporations is created.

The "Type F" is the mere change in , , or _____. or

In a reorganization the creditors rather than the shareholders are considered when testing the continuity of doctrine.

An equity structure shift occurs when a(n) causes an ownership change of percentage-points for any common shareholders owning at least 5%. A sale or issuance of stock can cause a(n) to take place.

The doctrine treats several transactions as if they were one transaction when they are all integrated. The doctrine ensures that the restructuring has a purpose beyond tax avoidance or evasion.

The acquisitive "Type D" reorganization differs from other restructurings in that the entity that transfers its assets is the corporation rather than the corporation.

Liabilities are problematic only in the reorganization when the corporation transfers other property as well as stock to the target.

A "Type A" reorganization that is the union of two or more corporations with one retaining its existence is called a . A is when a new corporation is created to take the place of two or more corporations.

One of the tenets of the U.S. tax policy is to business development. As an extension of this concept, corporate restructurings are given treatment.

If stockholders of the corporations involved in a tax-free reorganization receive in addition to stock, they may recognize gain. The character of the gain is either or . or or or

The tax treatment of the parties involved in a tax-free reorganization almost exactly parallels the treatment under the provisions. When boot is received, may be recognized but is not recognized.

The "Type C" reorganization requires that at least percent of the value of the target's assets be acquired with stock.

Since the reorganization precludes the use of boot, gain is not recognized in this type of reorganization. In this reorganization, a relationship between the acquiring and target corporations is created.