A direct conversion of an S corporation into a C corporation, or a merger of an S corporation into a C corporation, will produce only limited Section 1202 benefits, and only with respect to new stock ...
Hamilton Equity Group, LLC, as Assignee of HSBC Bank USA, National Association, successor by merger to HSBC Bank USA f/k/a Marine Midland Bank, successor by conversion to Marine Midland Bank, N.A.