Type "G" Reorganizations

Summary

This practice note discusses Type "G" reorganizations under Internal Revenue Code (IRC) Section 368. By comparison to an E reorganization, a "G" reorganization is a specific category of I.R.C. Section 368 reorganization intended to facilitate the restructuring or rehabilitation of distressed corporations in a Title 11 case. A "G" reorganization requires the transfer by a corporation of all or a part of its assets to an acquiring corporation. Thus, a "G" reorganization requires two parties—an acquiring and a target (or transferor) corporation. 2009 PLR LEXIS 9801.