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The Use Of Spinoffs: Tax Strategies To Dispose Of Corporate Assets

Webinar: ID# 1042685
Recorded On-Demand
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About This Course:
A spin-off of assets or stock by a corporation can incur significant corporate and stockholder-level tax if not properly structured. There are numerous and often esoteric requirements for a spin-off to qualify as a tax-free transaction for U.S. federal income tax purposes.

This presentation will help tax advisors and in-house tax practitioners understand the reasons when to pursue a tax-free spin-off, the requirements of a tax-free spin-off and common pitfalls in tax-free spinoff structuring.

This workshop will also discuss areas under current IRS study, recent revisions to the IRS private letter ruling policy, and alternative structures if a tax-free spin-off is not available.

Finally, this discussion will discuss issues specifically impacting technology and life science companies.What You'll Learn:When Does a Tax-Free Spinoff Make Sense?
  • Costs Versus Value
  • Operational Restrictions
  • Availability for Technology Companies
Basic Requirements and Structures
  • Statutory and Regulatory Requirements
  • Core Documents
  • Spin-off Structures
IRS Study and Rulings
  • Recent IRS Guidance and Regulations
  • Revisions to Private Letter Ruling Request Requirements and Ruling Policy
Alternatives
  • Tracking Stock
  • 336(E) Elections
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The Use Of Spinoffs: Tax Strategies To Dispose Of Corporate Assets
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