Tax Planning Strategies for S Corporation Mergers and Acquisitions
Asset vs. Stock Sales, 338(h)(10) and 336(e) Elections, Qualifying for Installment Sales Treatment, Built-in Gains Tax, and More
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax professionals guidance on tax challenges in S corporation mergers and acquisitions and available tax planning techniques. The panel will discuss key legal and tax considerations for both the buyers and sellers, the pros and cons of asset sales versus stock sales, qualifying for installment sales treatment as an S corporation, built-in gains tax, and taxation of the shareholders. The panel will also discuss 338(h)(10) and 336(e) elections and other critical tax issues that need to be accounted for to achieve the most beneficial tax outcome.
- Asset purchases and sales
- Stock purchases and sales
- F reorganizations
- Various transaction alternatives
- Installment sales
- Shareholder distributions
The panel will cover these and other critical issues:
- Pre-sale F reorganizations
- Avoiding built-in gains tax on sales
- When an election under 338(h)(10) would result in significant tax savings
- The differences between 338(h)(10) and 3336(e) elections
- How shareholders are taxed on dispositions
Caroline B. Banzali, J.D., LL.M.
Partner, Transaction Advisory
Ms. Banzali is a Partner with Withum’s Transaction Advisory Services Practice, specializing in tax due... | Read More
Ms. Banzali is a Partner with Withum’s Transaction Advisory Services Practice, specializing in tax due diligence, structuring, and post transaction integration and tax optimization planning. Her career as an M&A Tax professional spans nearly 25 years, including over a decade in the “Big 4”, several years as a senior “mega” Private Equity executive, and also served as tax counsel and head of risk management at a multi-billion-dollar tech start-up before returning to client service. Ms. Banzali's experience and background as both service provider and corporate executive has culminated in her unique arsenal of commercial business savvy coupled with technical expertise.Close
Daniel Mayo, J.D., LL.M.
Mr. Mayo has more than 20 years of professional tax experience as well as experience in federal, international and... | Read More
Mr. Mayo has more than 20 years of professional tax experience as well as experience in federal, international and financial products taxation. He is a member of Withum’s National Tax Services Group and oversees the U.S. Federal income tax research, planning and review functions. Mr. Mayo is experienced in mergers and acquisitions, capital markets and cross-border transactions.Close