This course is the fourth in a series of four courses covering the significant areas of corporate transactional taxation, including corporate organizations, dividends and other non-liquidating distributions, stock redemptions, liquidations, spinoffs and other corporate divisions, reorganizations and tax attributes.

This course starts by focusing deeply on the various classes of corporate reorganizations that are allowed non-recognition treatment for tax purposes. It then reviews the situations where loss carryovers, credit carryovers and other tax attributes are transferred between corporations. Finally, it analyzes provisions which can limit the use of such attributes. It addresses in detail the tax implications of those transactions to all affected parties, including shareholders as well as the participating corporations.

>In addition to discussing the key US tax provisions, regulations and case law, it describes planning considerations and discusses how the relevant tax rules apply to common fact patterns.

This course is ideal for tax professionals, financial accountants and management accountants that wish to develop or refresh expertise in corporate transactions. CFOs and other finance professionals who have some familiarity with tax and wish to increase their understanding of the area will also find it useful. 

Course Series

This course is included in the following series:

3 CoursesCorporate Transactional Taxation

  1. Corporate Transactional Tax I - Corporate Organizations, Contributions, Dividends and Non-liquidating Distributions
  2. Corporate Transactional Tax III - Corporate Liquidations, Section 338 and Acquisitions, Spinoffs and other Divisions
  3. Corporate Transactional Tax IV - Corporate Reorganizations, Carryover of Corporate Tax Attributes, and Limitations on Usage of Corporate Tax Attributes
Learning Objectives
  • Identify the various types of corporate stock and asset acquisition transactions that are allowed tax-free treatment under the reorganization provisions of the Internal Revenue Code, and recognize the principal tax provisions and interpretations (including regulations and case law) that can affect how those transactions are taxed.
  • Explore the tax provisions governing the treatment of corporate tax attributes (such as loss carryovers), including rules affecting their transfer between corporations and limitations on their utilization.
  • Recognize planning and structuring considerations and potential pitfalls concerning each type of reorganization transaction, and other transactions that can affect tax attributes. 
Last updated/reviewed: August 18, 2023
3 Reviews (16 ratings)


For those of us who are not tax accountants, this was way too advanced. I wanted to have a concept of tax implications when looking at acquisitions and mergers, but this training would require an interpreter for me. Don't even get me started on the corresponding quiz.

Anonymous Author
Too complex for time allotted and CPE questions too difficult.

Anonymous Author
Thanks Bro.

Course Complexity: Advanced

No Advanced Preparation or Prerequisites are needed for this course. However, it is recommended to take the other courses in the series prior to completing this one.

Education Provider Information
Company: Illumeo, Inc., 75 East Santa Clara St., Suite 1215, San Jose, CA 95113
Contact: For more information regarding this course, including complaint and cancellation policies, please contact our offices at (408) 400- 3993 or send an e-mail to .
Instructor for this course
Course Syllabus
Corporate Transactional Tax IV
  Principle Acquisitive Reorganization Types14:17
  Triangular and Type D Reorganizations 8:35
  Other Reorganization Types7:03
  Limitations on Reorganizations 11:12
  Treatment of Reorganization Parties10:46
  Tax Attributes 5:43
  Sections 382 - 384, Tax Attributes and Conclusion 13:04
Continuous Play
  Corporate Transactional Taxation IV1:22:18
  Slides: Corporate Transactional Tax IVPDF
  Corporate Transactional Tax IV Glossary/IndexPDF