Thats GENERALLY the case..but,the law says its taxable. However companies generally ask and get a ruling making it a tax free swap. Sometimes an issue can arise when a foreign company is involved as is the case here. I'm pretty sure that it'll will be ok, just didn't want you to think its a 100% sure thing. I dont know if this was addressed in the agreement or if they mentioned that they were looking to structure it as a tax free swap.