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Here is the IRS bulletin that applies to your question. F reorganizations are tax-free transactions if they involve “mere” changes in a taxpayer's name or jurisdiction. Here are the six requirements that must be met:
The requirements are:• immediately after a potential F reorganization, all stock of the resulting corporation must be distributed in exchange for stock of the transferor corporation in the potential F reorganization;• the same person or persons own all the stock of the transferor corporation at the beginning of the potential F reorganization and all of the stock of the resulting corporation at the end in identical proportions;• the resulting corporation doesn't hold any property or have any tax attributes immediately before the potential F reorganization;• the transferor corporation must completely liquidate in the reorganization for federal income tax purposes;• immediately after the potential F reorganization, no corporation other than the resulting corporation may hold property that was held by the transferor corporation immediately before the potential F reorganization; and• immediately after the potential F reorganization, the resulting corporation may not hold property acquired from a corporation other than the transferor corporation if the resulting corporation would, as a result, succeed to and take into account the items of such other corporation described in Section 381(c).
Can you please explain what you mean by disclosure requirements?
Item 9 of form 1120S states:
If the corporation was a C corporation in a prior year, or if it engaged in a tax-free reorganization with a C corporation, enter the amount of any accumulated earnings and profits (E&P) at the close of its 2015 tax year.
The only thing that I see that form 1120S requires on this is at item 9 since it is a tax-free reorg. If the IRS wants you to prove that up, then they will ask for it.