News & Analysis as of

Corporate Conversions

ArentFox Schiff

The ‘DExit’ That Never Happened

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When the Delaware Supreme Court held in Maffei v. Palkon that Tripadvisor’s reincorporation from Delaware to Nevada should be reviewed under the business judgement rule and not the entire fairness standard (all but ensuring...more

Fenwick & West LLP

Delaware Court of Chancery Upholds Tesla’s Texas Forum Bylaw Adopted After Filing of Derivative Suits

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On April 13, 2026, Vice Chancellor Bonnie David of the Delaware Court of Chancery dismissed three consolidated derivative actions against Tesla, Inc. and its directors, enforcing a Texas forum selection bylaw that was adopted...more

Foley & Lardner LLP

Delaware Chancery Rejects “Race to the Courthouse” in Enforcing Texas Exclusive Forum Bylaw, Dismissing Three Derivative Lawsuits...

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On April 13, 2026, the Delaware Court of Chancery dismissed three derivative suits in In re Tesla, Inc. Derivative Litigation based on Tesla’s forum selection bylaw requiring that those lawsuits be brought in Texas. All three...more

Polsinelli

Florida Passes Sweeping Modernization of State Nonprofit Law, Effective July 1

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Key Takeaways: HB 797 will comprehensively modernize the Florida Nonprofit Corporation Act, with changes taking effect July 1, 2026....more

Bass, Berry & Sims PLC

GAO: Conversion Did Not Void Procurement Eligibility

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In the matter of L3Harris Technologies Integrated Systems L.P., the Government Accountability Office (GAO) denied a protest filed by L3Harris challenging the U.S. Army’s award to Sierra Nevada Company, LLC for the Army’s...more

Rivkin Radler LLP

Converting a Taxable Corp Into a Tax-Exempt Entity Via a Bargain Sale – or is it Something More?

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From Taxable to Tax-Exempt Corp Travel back with me to 1986, if you will, and the repeal of the General Utilities doctrine. The Tax Reform Act of 1986 added Sec. 337(d) to the Code and directed the Treasury to prescribe...more

Rivkin Radler LLP

Tax-free Conversion of Corporation Into Partnership Via “C” Reorganization

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Under the Code and the Regulations issued thereunder, the gain or loss arising from the conversion of property into cash is treated as income realized or as loss sustained by the owner of the converted property, which the...more

Orrick, Herrington & Sutcliffe LLP

Risk and Reward: How Starting Your Business as an LLC Could Impact QSBS Tax Savings (UPDATE)

As a founder, deciding whether to organize your business as a corporation or a limited liability company (LLC) is a crucial first step. Corporations are often favored for their ability to attract venture capital and offer...more

Williams Mullen

[Event] 2025 Fall Tax Forum - November 5th, Richmond, VA

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Join Williams Mullen attorneys for our 2025 Fall Tax Forum, where we will dive into key developments shaping the U.S. federal tax landscape following the enactment of the One Big Beautiful Bill Act (the “OBBBA”) this past...more

Holland & Knight LLP

Converting from an S Corporation to Qualified Small Business Stock

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The One Big Beautiful Bill Act (OBBB) has spurred even more interest among businesses that may qualify for the tax benefits associated with qualified small business stock (QSBS), including businesses that currently are...more

Holland & Knight LLP

Conversion of Partnership and LLC Interests into Qualified Small Business Stock

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Given the recent amendments to Internal Revenue Code Section 1202,1 which increase the benefits of holding qualified small business stock (QSBS), many companies currently operating as tax partnerships may want to convert into...more

Shumaker, Loop & Kendrick, LLP

Client Alert: Business Relocation – Converting Your Entity to a Florida Domicile

Florida has long been a magnet for businesses seeking a favorable economic climate, lower tax burdens, and a pro-business regulatory environment. For entities looking to leverage these advantages by relocating, converting an...more

Hogan Lovells

Court of Chancery rules that supermajority voting provision did not apply to conversion

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In Gunderson v. The Trade Desk, Inc., the Delaware Court of Chancery held that a company’s conversion pursuant to Section 266 of the Delaware General Corporation Law (DGCL) did not require a supermajority vote because that...more

Allen Matkins

Should Nevada Corporations Say Goodbye To Ratification Of Auditor Appointments?

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According to this Form 8-K filed on April 29, 2025, Tripadvisor, Inc. finally completed its reincorporation from Delaware to Nevada by means of a statutory conversion, which it erroneously denominated a...more

Allen Matkins

Judge Rules Shareholders Can Pursue Derivative Claim Following A "Conversion"

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A year ago, I posited the question whether a derivative suit can survive a conversion. I raised that question in reference to Palkon v. Maffei, 2024 WL 678204 (Del. Ch. Feb. 20, 2024), in which the plaintiffs unsuccessfully...more

Morris James LLP

Court of Chancery Holds Supermajority Vote Not Required for Nevada Reincorporation

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Gunderson v. The Trade Desk Inc., C.A. No. 2024-1029-PAF (Del. Ch. Nov. 6, 2024) - The board of a Delaware corporation recommended that the corporation reincorporate as a Nevada corporation subject to a majority vote...more

Holland & Knight LLP

Delaware Supreme Court: Permissive Business Judgment Rule Applies to Corporate Conversions

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everal 2024 decisions by the Delaware Court of Chancery led some prominent corporate leaders to express frustration over perceived increased liability standards for corporate officers and directors, even publicly advising new...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part X – Converting a...

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When considering converting a C corporation to an S corporation, tax advisers and taxpayers need to pay careful attention to the many perils that exist. Failure to pay close attention to the road in this area could result in...more

Fenwick & West LLP

Domestication with a Twist: A Tax Case Study

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The Internal Revenue Service’s new private letter ruling (PLR) concerned a domestication of a Foreign Parent corporation under U.S. ownership—with a few notable twists. First, the PLR applied a substance-over-form analysis to...more

Allen Matkins

Can A Derivative Suit Survive Conversion?

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In Palkon v. Maffei, 2024 WL 678204 (Del. Ch. Feb. 20, 2024), the plaintiffs sought to enjoin the proposed conversions of TripAdvisor, Inc. and  Liberty TripAdvisor Holdings, Inc. into Nevada.  As noted in this post, Vice...more

Jones Day

Court of Chancery Applies Entire Fairness Standard to Conversion of Delaware Corporation to Nevada Corporation

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TripAdvisor and its controlling corporation, both publicly traded Delaware companies, announced plans to convert to Nevada corporations. Shareholders sued to enjoin the conversions, alleging that the boards of directors had...more

Venable LLP

Fiduciary Liability Limitations Under Nevada Law Trigger Entire Fairness Review of Conversion from Delaware Due to Controlling...

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The Delaware Court of Chancery, in Palkon v. Maffei, et al., C.A. No. 2023-0449-JTL (Del. Ch. Feb. 20, 2024), determined that a reduction in the liability exposure of a fiduciary due to the conversion of a Delaware...more

Lowenstein Sandler LLP

The New Jersey Business Corporation Act to Permit Corporate Conversions/Domestications

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Effective November 4, 2023, the New Jersey Business Corporation Act (the Act) will be amended to permit conversions and domestications across all business entity types, including foreign and domestic corporations. The delay...more

Rivkin Radler LLP

Pre-Consolidation Conversions in the Accounting World – Tax Considerations

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Another Change- Last week BDO confirmed that it was going to convert from an entity organized as a limited liability partnership under state law to one organized as a corporation. With that, BDO became the latest in a...more

Dorsey & Whitney LLP

New Minnesota Health Care Transaction Oversight Law Imposes Additional Requirements on Nonprofit Health Care Entities

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On May 26, 2023, the Governor of Minnesota signed into law Minnesota bill HF 402 to increase government oversight of health care transactions that occur in Minnesota or involve Minnesota-based health care entities....more

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