What about Tax on this stock dividend

The question is will there be a tax on this dividend as ordinary , cover or what. If there is will the tax be on a per share basis at the time it is issued , say today at $13.50 or at the diluted price after the dust settles and it adjusts for the increased number of shares issued. Will we be able to offset it as still under the price we paid for the original purchase of our stock before the reverse split because we are all underwater right now. Anyone an accoutant with an opinion on this?