Description
Understand the requirements of a taxfree spinoff and common pitfalls in taxfree spinoff structuring.A spinoff of assets or stock by a corporation can incur significant corporate and stockholderlevel tax if not properly structured. There are numerous and often esoteric requirements for a spinoff to qualify as a taxfree transaction for U.S. federal income tax purposes. This presentation will help tax advisors and inhouse tax practitioners understand the reasons when to pursue a taxfree spinoff, the requirements of a taxfree spinoff and common pitfalls in taxfree 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 taxfree spinoff is not available. Finally, this discussion will discuss issues specifically impacting technology and life science companies.
Date: 2024-09-17 Start Time: End Time:
Learning Objectives