Divisive Reorganizations and Separations

2 Credit Hours

This course, open to Tax LLM and JD students, focuses on corporate spin-offs and other transactions designed to qualify for tax-free treatment under section 355 of the Internal Revenue Code, including the interface of section 355 with the "reorganization" and various other corporate tax provisions of the Code. Powerpoint slides that present transactional formats and issues commonly encountered in practice will serve as the principal basis for class discussion. A hypothetical case study will serve as the basis for one or more required practitioner-oriented writing projects. The course grade will be based on the required writing project(s) and class participation. All course materials will be available on-line.