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.
- 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
- To prepare tax professionals to advise clients regarding the tax rules associated with corporate reorganizations
Tax professionals who advise clients regarding the tax consequences of a corporate reorganization.