equity structure shift
(3) Equity structure shift defined (A) In general The term “equity structure shift” means any reorganization (within the meaning of section 368 ). Such term shall not include— (i) any reorganization described in subparagraph (D) or (G) of section 368(a)(1) unless the requirements of section 354(b)(1) are met, and (ii) any reorganization described in subparagraph (F) of section 368(a)(1). (B) Taxable reorganization-type transactions, etc. To the extent provided in regulations, the term “equity structure shift” includes taxable reorganization-type transactions, public offerings, and similar transactions.