- 4 - substantial business reasons by way of a tax-free reorganization under section 368. As the culmination of the reorganization, CIGNA was incorporated on March 31, 1982, as the holding company for the surviving affiliated business entities. In years prior to the combination of the CG and the INA Groups, INA and its affiliates had filed consolidated Federal income tax returns, with INA as the common parent corporation of the affiliated INA Group. Members of the INA Group were engaged primarily in selling, underwriting, and servicing P&C insurance. The reorganization involving the CG and the INA Groups was treated as a reverse acquisition under section 1.1502-75(d)(3), Income Tax Regs. After the reorganization and for Federal income tax purposes, the CG Group was treated as continuing in existence and the INA Group was treated as ceasing to exist. CIGNA was treated as the common parent corporation of the continuing CG Group (the CIGNA Group), and companies that constituted members of the former INA Group became members of the CIGNA Group. Acquisition of PHC On November 20, 1984, an affiliate of CIGNA acquired 89.9 percent of the stock of Preferred Health Care, Inc. (PHC), in a taxable transaction. As a result of this transaction, PHC and its subsidiary companies (the PHC Group) terminated, and companies that constituted members of the former PHC Group became members of the CIGNA Group.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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