Special Purpose Acquisition Companies: Tax Structures, PFIC, QEF Election, and More
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax counsel and advisers an in-depth analysis of key tax challenges for special purpose acquisition companies (SPACs). The panel will discuss tax issues upon formation, tax considerations for structuring transactions, and key tax challenges for domestic and foreign investors. The panel will also discuss passive foreign investment companies (PFICs), the QEF election and other key tax provisions, rules, and reporting compliance.
Outline
- Overview of SPACs
- Tax considerations for structuring SPACs
-
SPAC formation tax Issues
-
De-SPACing tax structuring
-
- Tax objectives for U.S. investors
- Tax objectives for non-U.S. investors
- PFIC considerations in connection with SPACs
- Key tax provisions and best practices in structuring SPAC transactions
Benefits
The panel will review these and other key issues:
- What are the key tax considerations for forming SPACs?
- What are the tax implications for U.S. and non-U.S. SPAC investors?
- What are the potential international tax implications?
- How can a qualified electing fund election benefit U.S. shareholders?
- What are the key tax provisions for SPAC deal structures?
- What other key tax provisions, rules, and reporting compliance must be considered?
Faculty
Devon M. Bodoh
Partner
Weil Gotshal & Manges
Mr. Bodoh advises clients on cross-border mergers, acquisitions, inversions, spin-offs, other divisive strategies,... | Read More
Mr. Bodoh advises clients on cross-border mergers, acquisitions, inversions, spin-offs, other divisive strategies, restructurings, bankruptcy and non-bankruptcy workouts, the use of net operating losses, foreign tax credits, deficits and other tax attributes, and consolidated return matters.
Close
William S. Dixon
Managing Director
Citigroup Global Markets
Mr. Dixon is an investment banker and Managing Director at Citigroup Global Markets Inc., where he focuses on... | Read More
Mr. Dixon is an investment banker and Managing Director at Citigroup Global Markets Inc., where he focuses on tax-advantaged domestic and cross-border M&A transactions, capital structure solutions and financings for public and private companies, including mergers, acquisitions, divestitures, buy-outs, and SPAC transactions. He also is a member of the firm’s Fairness Opinion Committee.
Mr. Dixon has served as an adjunct assistant professor at Brooklyn Law School and taught classes on the taxation of securities and derivatives and the taxation of partnerships. He has also taught as an adjunct at the Peter J. Tobin School of Business at St. John’s University and has given guest lectures for classes at Harvard Law School and NYU’s Leonard N. Stern School of Business
Mr. Dixon currently serves on the Board of Directors of the International Tax Institute, is a member of the New York Steering Committee of the International Fiscal Association, and was formerly Chair of the U.S. Activities of Foreigners and Tax Treaties Committee of the ABA’s Section of Taxation. He is also a former John S. Nolan Fellow and also served on the ABA’s Task Force on International Tax Reform. Will speaks frequently about Federal income tax matters.
Prior to joining Citigroup, Mr. Dixon was a Senior Attorney at Cravath, Swaine & Moore LLP, a law firm in New York City; he earned his J.D. (magna cum laude) from Boston University School of Law.
Close