I.R.C. §(a)(3)(D): Reorganizing An Insolvent Savings and Loan Association

Whether or not the new reorganization provision, section 368(a)(3) (D), succeeds in inducing the acquisition of insolvent savings and loan associations, it is likely to be viewed as a creative attempt at a solution. To best illustrate the novelty of Congress's approach, the ensuing sections begin with an explanation of federal tax law as it has evolved in the context of insolvency reorganizations.