Corporate Transactional Tax IV – Corporate Reorganizations, Carryover of Corporate Tax Attributes, and Limitations on Usage of Corporate Tax Attributes

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.