The One, Big, Beautiful Bill Act (H.R. 1), recently passed by the U.S. House, introduces major changes to the Global Intangible Low-Taxed Income (GILTI) regime that could impact multinational corporations...
Class B malls have struggled in recent years with the decrease in mall shoppers and the departure of anchor tenants. Developers and owners are revitalizing Class B malls and filling vacancies by introducing...
Joint ventures bring together two or more parties to collaborate on a specific business opportunity. They may be structured as contractual arrangements, new entity formations, or investments in an existing...
This practice note covers how to respond to a complete response letter issued by the FDA as part of the agency’s new drug application (NDA) or biologics license application (BLA) process. Read...
Want to know how to balance the benefits of artificial intelligence tools against associated risks to employee privacy? Read our practice note, Artificial Intelligence (AI) and Employee Privacy , by Damon...
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A “G” reorganization is a specific category of I.R.C. § 368 reorganization intended to facilitate the restructuring or rehabilitation of a distressed corporation in a Title 11 bankruptcy case. A "G" reorganization requires the transfer by the corporation of all or a part of its assets to an acquiring corporation, so a "G" reorganization requires two parties—an acquiring and a target (or transferor) corporation. Be mindful to comply with the specific requirements outlined in Section 368 to maintain the tax-free treatment of the transaction, as failure to meet these requirements could result in adverse tax consequences for both the transferor and acquiring corporations.
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