3370 Tax-Free Acquisitions
Price: $ 119.00 (USD)
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You will receive 1.25 credits (CE) upon completion of this course.
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Course Description
The IRS has issued several rulings in the past few years that substantially modify and liberalize the rules for tax-free acquisitions. A panel of tax law experts, including a representative from the Office of Tax Policy in the U.S. Department of the Treasury, discusses these rulings, other recent guidance, and pending developments. The discussion focuses on ways of dealing with fluctuations in value and elective applications of 26 U.S.C. ��351.
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Course Outline
Tax-Free Acquisitions
I. Fluctuations in Value
A. Relevant Laws and Requirements
B. Continuity of Proprietary Interest
1. Base Example
2. Measuring Continuity of Interest at Signing
3. Reverse Subsidiary Merger
4. Valuing Stock at Signing
5. Authorities on Valuation at Signing
6. Policy Perspective
7. Additional Considerations
C. Statutory Provisions
D. Variable Stock Consideration
E. Drop-Down of Assets
1. Revenue Rulings
2. Open Questions
F. Push-Up of Assets
G. Two-Step Transaction
II. Elective Applications of 26 U.S.C. § 351
A. Broken § 351 Transaction (1)
B. Broken § 351 Transaction (2)
C. Combination § 351 Transfer and Purchase
D. Variation on Prior Example (1)
E. Variation on Prior Example (2)
F. Characterization Issue
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I. Fluctuations in Value
A. Relevant Laws and Requirements
B. Continuity of Proprietary Interest
1. Base Example
2. Measuring Continuity of Interest at Signing
3. Reverse Subsidiary Merger
4. Valuing Stock at Signing
5. Authorities on Valuation at Signing
6. Policy Perspective
7. Additional Considerations
C. Statutory Provisions
D. Variable Stock Consideration
E. Drop-Down of Assets
1. Revenue Rulings
2. Open Questions
F. Push-Up of Assets
G. Two-Step Transaction
II. Elective Applications of 26 U.S.C. § 351
A. Broken § 351 Transaction (1)
B. Broken § 351 Transaction (2)
C. Combination § 351 Transfer and Purchase
D. Variation on Prior Example (1)
E. Variation on Prior Example (2)
F. Characterization Issue
AfterWordsSM
More Information
| Language | English |
| Course Length | 1.37 hours |
| Duration of Access | for 3 months from day of enrollment |
| Continuing Education Credits | 1.25 |
| Instructor | John J. Clair, Matthew A. Rosen, Michael L. Schler, Eric Solomon, Thomas F. Wessel |
| Vendor | Cognistar (Read more about Cognistar accreditation.) |
| Course Certification | CLE credit available, see details for each course for states where available |
| Prerequisites/Audience | intended for attorneys and law students |
| Requirements/Materials Included | computer with Internet access |
Price: $ 119.00 (USD)
Add to Cart