Surgent's An Introduction to Tax-Free Reorganizations (ITFR)

Description

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.

Highlights

• 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

Objectives

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

Designed For

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