For each item, decide whether the transaction qualifies as an A reorg, B reorg, C reorg, or if the transaction is taxable. Each category (A, B, C, etc.) might be used more than once; and not all categories may needed. P and T are both C corporations.
P makes a tender offer directly to the shareholders of T to acquire the T stock in an exchange of one share of P voting common stock for each share of T stock. All of the T shareholders accept the tender offer. [ Taxable, A Reorg, B Reorg, or C Reorg ]
Pursuant to a purchase and sale agreement, T transfers all of its assets to P for 900 shares of voting common stock of P worth $900,000 and $100,000 of cash. P assumes all of T’s liabilities ($200,000) in the transaction. T liquidates and distributes the P stock and cash to its shareholders. [ Taxable, A Reorg, B Reorg, or C Reorg ]
P makes a tender offer directly to the shareholders of T to acquire the T stock in an exchange of one share of P voting common stock worth $95 and $95 of cash for each share of T stock. All of the T shareholders accept the tender offer. [ Taxable, A Reorg, B Reorg, or C Reorg ]
Pursuant to a state law statute governing mergers, T is merged into P. The T shareholders surrender their T stock in exchange for P voting stock. [ Taxable, A Reorg, B Reorg, or C Reorg ]