The process of structuring merger and acquisition transactions and living with their aftermath can lead to tax pitfalls and opportunities. This seminar will give participants an opportunity to consider both the upside and the downside of the corporate tax rules for mergers & acquisitions, led by a team from KPMG’s Washington National Tax Office who deal with such issues on a daily basis.
Starting with a review of the core tax principles and key issues underling taxable and tax-free acquisitions, this seminar will focus on the issues that challenge transactional planning, as well as consider a variety of discrete issues including cross-border transactions under Sections 367/7874, consolidated returns, section 355 stock distributions, insolvent corporations, internal restructurings, use of losses, economic substance/step-transaction, and transaction costs.
Also, the course will address the recent section 385 debt-equity regulations
- potentially the most significant change to corporate tax principles since 1986
- focusing on the building blocks of its general operation as well as delving into the detail of the rules to identify ancillary issues and address the specific needs of the participants.
5/17-5/18/2017 San Diego
Venue and Hotel Details
- Taxable asset Sales, Section 338, and Section 336(e)
- Tax-Free Reorganizations and Section 355
- Economic Substance, Step-Transaction, and Substance-Over-Form
- Consolidated Returns Issues
- International Issues Under Sections 367 and 7874
- Tax Treatment of Transaction Costs
- New Section 385 Regulations
- Cancellation of Indebtedness
- Loss Issues
Level of Knowledge:
Field of Study:
Group Live, Instructor-Led Course
Partners and Senior Managers from KPMG's Washington National Tax Office.
* Discounts cannot be combined and must be applied at time of initial registration.
** Tuition price includes daily breakfast, lunch, and morning and afternoon refreshments.