Tax-Free Restructuring Reorganization: Type E


This practice note provides an overview of tax-free type E reorganizations under I.R.C. Section 368(a)(1)(E) (E Reorganizations), which include bonds exchanged for stock, stock exchanged for bonds, bonds exchanged for bonds, and stock exchanged for stock. The practice note begins by examining the E Reorganization requirements. Then it describes the complexities of E Reorganizations as set forth in the Treasury Regulations Section 1.368-2(e)(1)-(5). Lastly, the practice note discusses the business purpose for an E Reorganization.