Tax Issues in Corporate Mergers & Acquisitions: Part 2

Author: Jennifer Kowal

Part 2 of Tax Issues in Corporate Mergers & Acquisitions explains the types of reorganizations that occur within a merger acquisition.

This course covers the federal income tax treatment of taxable stock and asset acquisitions, tax-free reorganizations and acquisitions, and tax-free dispositions and spin-offs, from both the corporate and shareholder perspectives. It also covers the carryover of corporate tax attributes.

Publication Date: December 2017

Designed For
Tax practitioners at all levels who advise on the taxation of corporate mergers, acquisitions, and disposition transactions.

Topics Covered

• Dispositions of Unwanted Assets Prior to Sale of Business
• Divisive Reorganizations
• Single Entity Reorganizations
• Subsidiary Single Entity Reorganizations
• Capitalization of Transaction Costs
• Combining Tax Attributes

Learning Objectives

• Differentiate correct statements regarding the parent basis in sub stock
• Describe IRC Section 354(a)(1) prescribes that gain or loss recognition
• Recognize types of divisive reorganizations results in a distribution of sub stock
• Identify consideration of shareholder tax treatment with respect to divisive reorganizations
• Describe types or reorganizations
• Recognize which IRC Sections of new debt represent a significant modification
• Identify types of single entity reorganization
• Differentiate Indopco and Anti-Indopco regulations

Level
Intermediate

Instructional Method
Self-Study

NASBA Field of Study
Taxes (4 hours)

Program Prerequisites
Basic experience with corporate mergers and acquisitions.
Completing CPE course Tax Issues in Corporate Mergers & Acquisitions: Part 1

Advance Preparation
None