Grebe Corporation is a car dealership that has been in existence for 10 years. It has also been in the car leasing business for 6 years. Both businesses produce substantial amounts of cash, and Grebe has been investing this cash in mutual funds for the past 10 years. Grebe is interested in separating its businesses. It will create (a) new corporation(s) to receive assets in exchange for stock. Which of the following is correct regarding this transaction?
A) Grebe must distribute at least 80% of the new corporation(s) stock to its shareholders in exchange for a proportionate amount of Grebe's stock. If the shareholders do not exchange stock, the transaction receives dividend treatment.
B) Grebe may create up to 3 new corporations because it has 3 lines of business. If 3 new corporations are created, Grebe ceases to exist because it will have no assets.
C) The new corporations created will carry over no tax attributes or earnings and profits from Grebe.
D) Using a split-off "Type D" reorganization, Grebe can transfer the car leasing business to the new corporation and exchange the new corporation stock for some of the Grebe stock held by its shareholders.
E) All of the above statements are correct.
Correct Answer:
Verified
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