INCOME TAX

Rev. Rul. 2001–24, page 1290. Forward triangular merger. A controlling corporation’s transfer of the acquiring corporation’s stock to another controlled subsidiary as part of the plan of reorganization, following the merger of the acquired corporation with and into the acquiring corporation, will not cause the transaction to fail to qualify as a reorganization under sections 368(a)(1)(A) and 368(a)(2)(D) of the Code.

Rev. Rul. 2001–25, page 1291. Reverse triangular merger. A reverse triangular merger qualifies as a tax-free reorganization under sections 368(a)(1)(A) and 368(a)(2)(E) of the Code, notwithstanding that immediately after the merger, and as part of a plan that includes the merger, the surviving corporation sells a portion of its assets to an unrelated party for cash that it retains.