Section 336(e) Elections: Tax Basis Step-Up Through Deemed Asset Sale Treatment
Structuring Qualifying Stock Dispositions for Partnership and Private Equity Acquirers and...
November 12, 2020 • CLE, CPE, EA • CLE On-Demand, Download
This CLE/CPE course will provide tax advisors with a thorough and practical guide to utilizing a Section 336(e) step-up election in the disposition of a target corporation. The panel will contrast the Section 336(e) election with the election available under Section 338(h)(10), outline the requireme...
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 course 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 course 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.
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...