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    IRS Form 1099-CAP

    Form 1099-CAP: Changes in Corporate Control and Capital Structure

    Report changes in corporate control or capital structure that affect the basis of securities.

    Filing Deadline

    January 31 (to shareholders) / February 28 (paper) or March 31 (e-file) to IRS

    Who Receives

    Shareholders affected by acquisition or substantial capital structure change

    Purpose

    Reports basis information for securities involved in corporate transactions

    Overview

    Form 1099-CAP is used by corporations to report changes in control or capital structure that affect shareholders' basis in their stock or securities. This typically occurs during acquisitions, mergers, or significant restructurings.

    The acquiring corporation must file this form when it acquires control or substantially all assets of another corporation in exchange for stock, and cash or other property is paid to shareholders.

    Who Must File

    Required Filers

    • Acquiring corporations that obtain control of another corporation in exchange for stock
    • Corporations that acquire substantially all assets of another corporation
    • Required when cash or other property (boot) is paid to target shareholders
    • Must file for each shareholder of record who receives cash or property

    Exceptions & Notes

    • Not required if no cash or property is exchanged (stock-for-stock only)
    • Certain reorganizations under IRC section 368 may have modified requirements

    Form Structure & Instructions

    Here's what information is required in each section:

    Corporate Action Information

    Details about the acquisition or restructuring

    Box 1
    Date of Sale or Exchange
    Closing date of the acquisition
    Box 2
    Aggregate Amount
    Total cash and FMV of property received
    Box 3
    Number of Shares
    Number of shares exchanged by shareholder
    Box 4
    Classes of Stock
    Description of stock classes exchanged

    Tax Information

    Tax-related details of the transaction

    Box 5
    Organizational Action
    Code describing the type of corporate action
    Box 6
    Cash in Lieu of Fractional Shares
    Cash paid instead of fractional shares

    Important Filing Notes

    Acquisition of Control

    Control generally means ownership of at least 80% of voting power and 80% of each class of nonvoting stock. Report when this threshold is met.

    Substantially All Assets

    The acquisition of substantially all assets typically means at least 70% of gross assets and 90% of net assets, though specific facts matter.

    Shareholder Basis

    This form helps shareholders calculate their basis in new securities received and determine gain or loss on any boot (cash/property) received.

    Statement Requirement

    Must also provide shareholders with a detailed written statement explaining the tax treatment of the transaction within 45 days.

    Expert Corporate Transaction Reporting

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