Structuring Shareholder NOL Rights Plans: Section 382 Implications, Tax Issues, Key Provis...
Leveraging NOL Carryforwards for Companies Amid Distressed Stocks and Low Interest Rates
September 29, 2020 • CLE, CPE, EA • Live Webinar
This CLE/CPE webinar will guide to tax and M&A counsel on key tax considerations and provisions for structuring shareholder net operating loss (NOL) rights plans. The panel will discuss the differences of NOL rights plans and traditional shareholder rights plans, implications of ownership changes un...
Tax Pitfalls of Offshore M&A: Planning Techniques to Avoid Unintended Tax Liability
Impact of New Tax Law on Deal Structures, Section 163(j), GILTI, Transfers Under Section 3...
August 21, 2019 • CLE, CPE, EA • CLE On-Demand, Download
This CLE/CPE webinar will discuss the most important changes impacting U.S. taxation of multinational entities and how these changes affect planning for cross-border deals. Specifically, the panel will discuss planning techniques in light of the new Section 163(j) limitations on interest deductions,...
IRC Section 338(h)(10) Election Strategies for Tax Counsel
Leveraging the Election in Structuring Acquisitions, Dispositions, Asset and Stock Transfe...
March 27, 2019 • CLE, CPE, EA • CLE On-Demand, Download
This CLE/CPE webinar will provide tax counsel with a review of the application, operation, and impact of the Section 338(h)(10) election. The panel will provide tax planning strategies to optimize tax benefits and minimize pitfalls in the election under the new tax law.
Section 336(e) Elections: Tax Basis Step-Up Through Deemed Asset Sale Treatment
Structuring Qualifying Stock Dispositions for Partnership and Private Equity Acquirers
November 14, 2018 • CLE, CPE, EA • CLE On-Demand, Download
This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to utilizing a Section 336(e) step-up election in the acquisition of a target corporation. The panel will contrast the 336(e) election with 338(h)(10) treatment, outline the requirements for qualification, and detail t...
Taxation of Cross-Entity Mergers and Conversions
Navigating Complex IRS Rules to Merge or Convert LLCs, S Corps and C Corps
February 29, 2012 • CLE, CPE • CLE On-Demand, Download
This teleconference will provide tax counsel with an examination of federal income tax consequences of merging or converting LLCs and partnerships. The panel will provide best practices for entity selection that anticipates long-term business strategies and to structure mergers and acquisitions to o...