A type C reorganization is a stock-for-assets reorganization with the requirement that at least 50% of the FMV of the target's assets, as well as the assumption of certain specified liabilities, are acquired solely in exchange for voting stock.

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A type C reorganization is a stock-for-assets reorganization but it requires that substantially all of the properties of the target are acquired, not just 50% of the FMV of the target's assets.

A Type C Reorganization Is a Stock-For-Assets Reorganization with the Requirement