Tiburon Corp. proposes to acquire Target Corp. in a tax-deferred triangular merger using its 100%-owned Subsidiary Corp.

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Tiburon Corp. proposes to acquire Target Corp. in a tax-deferred triangular merger using its 100%-owned Subsidiary Corp.

The sole shareholder of Target will receive

$350,000 of Tiburon Corp. voting stock and

$200,000 cash as a result of the merger.

a. Can the proposed transaction qualify as a Type A forward triangular merger?

Explain.

b. Can the proposed transaction qualify as a Type A reverse triangular merger?

Explain.

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CCH Federal Taxation Basic Principles 2020

ISBN: 9780808051787

2020 Edition

Authors: Ephraim P. Smith, Philip J. Harmelink, James R. Hasselback

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