Tax-Free Acquisitive Reorganizations: Triangular Reorganizations | Practical Law
A Practice Note providing an overview of tax-free acquisitive reorganizations that are structured as triangular reorganizations. Unlike a direct tax-free acquisitive reorganization, which involves two parties (the target corporation and the acquiring corporation), a triangular reorganization typically involves three parties: the target corporation on the seller side and a parent corporation and a subsidiary (typically wholly owned) on the buyer side.