Liz Stieff published “Tax-Free Restructuring Reorganization: Type F” in Lexis Nexis. The following is an excerpt:
This practice note discusses tax-free reorganizations structured as Type F reorganizations under Internal Revenue Code (I.R.C.) § 368(a)(1)(F) (F reorganizations), including changes in identity, form, or place of organization of a corporation. The note explains common transaction structures, practical uses, and addresses key compliance considerations, including employer identification number (EIN) issues and federal income tax return reporting and filing requirements.