An Introduction to Tax-Free Reorganizations (ITFR)

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Overview

2.0 Credits
ONLINE

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.

Objectives

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

Major Topics

  • 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

Designed For

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

Prerequisite

None

Advanced Preparation

None