§1924

t a merger with a 90%-owned subsidiary without obtaining the approval of the subsidiary’s board or the parent’s shareholders, similar to current Delaware law (§ 1924(b)).”)9 Cautious practitioners 9 The parties have stipulated that under a short-form merger a “shareholder vote” is not required, but it is unclear whether the stipulation is referring to a vote of the shareholders of the subsidiary or a vote of the shareholders of both the parent and the subsidiary.