M&A and Tax Reform: New Deal Structure Considerations
Capital Expensing, Transition Tax, Business Interest Deduction, NOL Carryforwards, Executive Compensation and More
Recording of a 90-minute CLE webinar with Q&A
This CLE webinar will examine provisions of the new tax reform law that could have a significant impact on the structuring of mergers and acquisitions. The panel will discuss the steps counsel should take now with M&A deals in process, and upfront issues to consider in transactions going forward.
- Tax reform—background and timeline for implementation
- Limitations on use of net operating losses
- Transition tax on deferred foreign income
- Immediate capital expensing
- Tax on sale of foreign partnership interests
- Limitations on business interest expense deductions
- Changes to Code §162(m)—executive compensation
The panel will review these and other key issues:
- How has tax reform changed the analysis of a stock sale vs. asset sale structure?
- What is the significance of the new limitations on the deductibility of NOLs and business interest expenses?
- What is the one-time transition tax and might it impact deal structure?
- How could the changes to Code §162(m) impact executive compensation packages for a target company?
Griffin H. Bridgers
Hutchins & Associates
Mr. Bridgers' practice encompasses all areas of private wealth and family business. In addition to estate... | Read More
Mr. Bridgers' practice encompasses all areas of private wealth and family business. In addition to estate planning and estate administration, he is experienced in mergers and acquisitions, taxation, business transactions, franchising, commercial contracts, asset protection, executive compensation, employee benefits, qualified and non-qualified retirement plans, and nonprofit organizations. He counsels closely-held and family businesses, and nonprofit organizations, with their planning, succession, and liquidity needs in a variety of industries including tech, restaurant and retail, healthcare, manufacturing, construction, real estate, financial services, consulting, and professional staffing.Close
Russell A. Daniel
Mr. Daniel leads Grant Thornton’s Southeast Region Mergers & Acquisitions Tax Services practice. He assists... | Read More
Mr. Daniel leads Grant Thornton’s Southeast Region Mergers & Acquisitions Tax Services practice. He assists clients in identifying and evaluating tax risks and opportunities in connection with transactions, including M&A, and implementing federal tax planning strategies. With more than 23 years of experience, he has worked with numerous financial and strategic buyers in structuring acquisitions, buyouts, recapitalizations and internal reorganizations. He is experienced in leveraged buyouts, acquisitions of financially troubled companies, tax-basis planning, transaction cost analysis, S corporations, net operating loss and Section 382 planning, and bankruptcy.Close
Scott P. Greiner, LL.M. (Tax)
Mr. Greiner counsels clients on how to effectively structure clients' businesses, oil and gas and real estate... | Read More
Mr. Greiner counsels clients on how to effectively structure clients' businesses, oil and gas and real estate ventures, as well as insulate wealth from transfer taxes. He provides invaluable guidance on selecting tax-advantageous business entities, identifying opportunities to increase after-tax income, structuring deferred and reverse like-kind exchanges, planning business expansions and acquisitions, and transferring wealth generationally in a tax-wise manner. He frequently writes and lectures on a variety of sophisticated tax topics.Close