What is a reorganization?
Reorganizations are considered to be nontaxable events and will exist if the reorganization can demonstrate a continuity of business. A continuity of business means that the company will be able to continue operating or continue business operations subsequent to the reorganization.
Note that these differ from liquidating distributions in the sense that the company is not liquidating its assets are offering a selloff to dissolve, but rather is reorganizing its corporate structure.
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