lesn: 26 U.S. Code § 368 (Definitions relating to corporate reorganizations) does not "recognizes three types of corporate acquisition structures that qualify as tax-free (or tax-deferred) reorganizations." Give it a search for the term 'tax.'
All Nantworks has to do is convert to a C and do an IPO. A RTM cannot be done with the parent LLC, Nantworks. By definition, a RTM is done with a subsidiary of the corporation. So it has to be an IPO.
“It ain’t so much the things we don’t know that get us into trouble. It’s the things we know that just ain’t so.” Henry Wheeler Shaw