The Use of Spin-Offs: Tax Strategies to Dispose of Corporate Assets (OnDemand Webinar)

$219.00

SKU: 408259EAU

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 stockholder level tax if not properly structured, and there are numerous and often esoteric requirements for such a spinoff to qualify as a taxfree spinoff for U.S. tax purposes. This topic 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 material will also discuss areas that are under current IRS study and alternative structures if a taxfree spinoff is not available. Finally, this information will discuss issues specifically impacting technology and life science companies.

Date: 2021-03-26 Start Time: End Time:

Learning Objectives

When Does a Tax-Free Spin-Off Make Sense?
• Costs Versus Value
• Operational Restrictions
• Availability for Technology Companies

Basic Requirements
• Statutory and Regulatory Requirements
• Ruling Requirements

IRS Study and Rulings
• Hot Dog Stand Ruling
• IRS Study of Active Trade or Business Requirement for Entrepreneurial Businesses
• Recent Revenue Procedures

Alternatives
• Tracking Stock
• 336(e) Elections

AIPB ,CLE (Please check the Detailed Credit Information page for states that have already been approved) ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.

Myra Sutanto Shen-Wilson Sonsini Goodrich & Rosati