ETAX Corporation Reorganizations R17-211X

Provide the requirements for a Type C reorganization.

• Substantially all of the assets of the target is acquired in exchange for only voting stocks of the acquiring firm.
• The voting stocks must be at least 80% of the consideration provided.
• The target firm distributes stock and other assets to its stakeholders.
• Substantially all is defined by IRS as 90% of net asset value and 70% of gross asset value.