The requirements for tax deferral in a forward triangular merger and a reverse triangular merger are the same.
The requirements for tax deferral in a reverse triangular merger are more restrictive than in a forward triangular merger.

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The Answer of The requirements for tax deferral in a forward triangular merger and a reverse triangular merger are the same.
The requirements for tax deferral in a reverse triangular merger are more restrictive than in a forward triangular merger.

The Requirements for Tax Deferral in a Forward Triangular Merger