[Verse 1]
When companies collide and merge their fate
Type A brings statutory consolidation straight
Two become one through legal transformation
Stock and assets join in corporation
Type B swaps equity for equity shares
Stock-for-stock while independence declares
Type C trades stock for all the assets clean
Liquidation follows what we've seen
[Chorus]
A-B-C-D-E-F-G
Seven pathways through reorganization spree
Continuity of interest must remain
Business enterprise through the legal change
Boot recognition triggers taxable gain
Attributes carry forward in the chain
[Verse 2]
Type D divides or brings acquisitions near
Divisive splits or transfers crystal clear
Type E recapitalizes what exists
New structure from the old that still persists
Type F just changes identity or place
Same company with a different face
Type G emerges from bankruptcy's embrace
Creditors and debtors find their space
[Chorus]
A-B-C-D-E-F-G
Seven pathways through reorganization spree
Continuity of interest must remain
Business enterprise through the legal change
Boot recognition triggers taxable gain
Attributes carry forward in the chain
[Bridge]
Section three-eight-one preserves the past
Net operating losses transfer fast
But three-eight-two limitation cuts
Annual usage when ownership shuts
Continuity tests guard the door
Fifty percent or bust, nothing more
[Verse 3]
Boot means cash or property received
Beyond the stock that reorganization conceived
Recognition hits when boot appears
Taxable gain crystallizes here
Historical attributes migrate through
Earnings, profits, basis carry too
Unless the ownership change breaks the thread
Three-eight-two limits what lies ahead
[Outro]
Tax-free treatment when the rules align
Reorganization's grand design
Seven letters spell the corporate way
From merger dawn to bankruptcy's new day