§ 368

Rev. Rul. 77-191: Indirect spin treated as D/355

Rev. Rul. 73-427: Multistep acquisition treated as exchange

Rev. Rul. 66-224: COI satisfied where 50% of the shareholders receive cash

Rev. Rul. 88-48: Sale of half of assets before C reorg

Rev. Rul. 78-47: Transfer of assets to sub is downstream C reorg

Rev. Rul. 85-197: Holdco merger with sub satisfies COBE

Rev. Rul. 84-71: COI not required in a § 351 despite reorg overlap

Rev. Rul. 2017-9, Sit. 2: North-South Ruling - Distribution pursuant to a plan

Rev. Rul. 2003-51: Successive § 351 exchanges and control requirement

Rev. Rul. 2017-9, Sit. 1: North-South Ruling - Transfers treated as separate

Back to all resources

Get Started

Start enjoying better, faster analysis with Blue J

Whether you have questions or are interested in booking a demo, we would love to hear from you.