1. Short title This Act may be cited as the Stop Subsidizing Giant Mergers Act . 2. Modification of rules relating to corporate reorganizations for certain large corporations (a) Acquisitive reorganizations Section 368(a)(2) of the Internal Revenue Code of 1986 is amended by adding at the end the following new subparagraph: (I) Special rules with respect to certain acquisitive reorganizations described in paragraph (1)(A), (1)(B), (1)(C), and (1)(D) (i) In general A merger, consolidation, acquisition, or transfer which is described in clause (ii) shall not be treated as a merger, consolidation, acquisition, or transfer described in paragraph (1)(A), (1)(B), (1)(C), or (1)(D). (ii) Transactions described A merger, consolidation, acquisition, or transfer is described in this clause if— (I) such merger, consolidation, acquisition, or transfer is, or is treated as, the acquisition of the stock or assets of another corporation, (II) such merger, consolidation, acquisition, or transfer is not excepted under clause (iii), and (III) the combined average annual gross receipts of the acquiring corporation and the acquired corporation for the 3-taxable year period which precedes the taxable year in which the merger, consolidation, acquisition, or transfer is completed exceeds $500,000,000. (iii) Exceptions A merger, consolidation, acquisition, or transfer is excepted under this clause if— (I) either the acquiring corporation or the acquired corporation controls the other immediately before (and, if both corporations continue to exist, after) the merger, consolidation, acquisition, or transfer (as the case may be), (II) any other corporation controls both the acquiring corporation and the acquired corporation immediately before (and, if both corporations continue to exist, after) the merger, consolidation, acquisition, or transfer (as the case may be), or (III) either the acquiring corporation or the acquired corporation meets the gross receipts test of section 448(c)(1) for the taxable year in which the merger,