Extract to table

See Code § 1032(a) ("No gain or loss shall be recognized to a corporation on the receipt of money or other property in exchange for stock (including treasury stock) of such corporation

To qualify as a tax-free recapitalization, the following requirements must generally be satisfied: (i) Stock-for-Stock Exchange of Same Corporation

The transaction must involve an exchange of stock (or securities) of a corporation for stock (or securities) of the same corporation

There must be a plan of reorganization

The transaction must be motivated by a legitimate business purpose

For founders and early investors with low basis in their Lumos stock, the 10× basis alternative may provide a significantly higher exclusion limit than the $10 million fixed cap, but the specific limit must be calculated on a case-by-case basis