Mergers and Acquisitions »
Mergers and Acquisitions invoke tax, corporate, workforce, regulatory and other issues that each must be addressed with precision and care. The M&A structures have tax consequences even if the transaction is a non-taxable event. The rise of cross-border transactions and international entities are compounding the complexities. This focus center provides information about various issues and tax considerations that come into play when engaging in M&A transactions.
What You Need to Get Done Now If You Want to Sell Your Company in 2012
One of today’s most discussed political topics is the expected expiration of the Bush tax cuts after December 31, 2012. If Congress doesn’t act, among other things, the individual U.S. federal income tax rate
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338 Election
Top Takeaways 1: 338 Election Treats a Stock Purchase as an Asset Purchase A company can make a 338 election to treat the stock purchase as a hypothetical asset purchase. This way the buyer
Read More »Corporate Tax Deferred Reorganizations
Top Takeaways 1: Corporate Reorganizations can be classified into three types Corporate reorganizations are typically broken into three categories: those where the corporation grows; those where the corporation is divided up; and all others.
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Corporate Taxable Acquisition
Top Takeaways 1: Corporate Acquisition May be a Stock or Asset Purchase When a corporation is purchased, the deal may be structured as either a purchase of the corporation’s stock or assets. There are
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Tax Court Finds Offshore Portfolio Investment Strategy Lacks Economic
The U.S Tax Court, in a decision by Judge Kroupa, found the Offshore Portfolio Investment Strategy (OPIS) transaction lacked economic substance in Blum v Commissioner, T.C. Memo 2012-16 and held the parties responsible for
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