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Jul 30, 2020 · Types Of Reorganizations A business that wants to improve efficiency or improve profitability may restructure the way the company works to achieve one or both of those objectives. This process of restructuring is what is called corporate reorganization. The IRS ruled the conversion to an LLC followed by an election to be taxed as a corporation for federal tax purposes would be a tax-free reorganization under section 368(a)(1)(F). The S election would not be terminated as a result of this reorganization, and the usual basis carryover rules would apply. The Voting Stock Requirements. To meet the "Type B" reorganization requirements, the acquiring corporation's sole consideration must be voting stock, 11 and the acquiring corporation must be in "control" of the target corporation immediately after the reorganization. Control for this purpose requires owning at least 80 percent of all classes of the target corporation's stock.Aug 01, 2014 · All § 332 liquidations and asset reorganizations described in § 368(a)(1) in which a domestic corpora- tion acquires the assets of a foreign corporation.1 2. This includes straight A mergers, liquidations, and acquisitive asset reorganizations, such as forward triangular mergers, C reorganizations and D reorganizations.