TAX-867 Mergers & Acquisitions Taxation
This course examines the IRC corporate provisions of both tax-free and taxable acquisitions and reorganizations in relation to various acquisitive and reorganizational transactions. Topics include acquisition methods such as asset purchase, stock purchase, and contribution and acquisition combinations. Topics also covered include the continuity of enterprise and interest issues in conjunction with the tax treatment accorded a transaction, carryovers, limitations, basis, and consolidated tax returns. The course incorporates professional tax practice via the implementation of a case study approach which requires the examination of Code provisions, case law and current tax practice in devising a tax strategy that identifies the most tax advantaged acquisition or reorganization based on an assigned fact pattern, and the completion of a consolidated tax return.
Offered
Spring