Basic forward triangular merger
In Rev. Rul. 99-6, the IRS provides that certain transfers of partnership interests cause termination of a partnership.
In Rev. Rul. 99-6, the IRS provides that certain transfers of partnership interests cause termination of a partnership.
Section 368(a)(2)(D) Use of stock of controlling corporation in paragraph (1)(A) and (1)(G) cases
The acquisition by one corporation, in exchange for stock of a corporation (referred to in this subparagraph as “controlling corporation”) which is in control of the acquiring corporation, of substantially all of the properties of another corporation shall not disqualify a transaction under paragraph (1)(A) or (1)(G) if—
(i) no stock of the acquiring corporation is used in the transaction, and
(ii) in the case of a transaction under paragraph (1)(A), such transaction would have qualified under paragraph (1)(A) had the merger been into the controlling corporation.