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An Introduction to Tax-Free Reorganizations (ITFR)

Tuesday, December 13, 2016
01:00 PM - 03:00 PM (Eastern)

Mike Tucker, Ph.D., LL.M., J.D., CPA

Ian Redpath, J.D., LLM

  • Format Webinar
  • Credits 2
  • Level Intermediate
  • Field of Study Taxes (2)

Overview

During the life of a business conducted as a corporation, circumstances sometimes arise that cause a corporation to alter the form in which it conducts its business. One approach to altering the form of a business but not incurring tax is to take advantage of the provisions allowing for tax-free reorganizations of corporations. This program discusses the various types of reorganizations and the requirements that must be satisfied if reorganization is to be considered a nontaxable transaction.

Major Topics:

  • General requirements for a tax-free reorganization
  • Continuity of interest
  • Continuity of business enterprise
  • Acceptable patterns of reorganization—Types A-G
  • Judicial limitations
  • Plan of reorganization
  • Tax consequences of a reorganization to the shareholders, the acquiring corporation and the target
  • Carryover of tax attributes in a reorganization

Learning Objectives

  • To prepare tax professionals to advise clients regarding the tax rules associated with corporate reorganizations

Who should take this course:

Tax professionals who advise clients regarding the tax consequences of a corporate reorganization.

None

None

Yes

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