Advanced Corporate Tax: Tax-Free Mergers & Acquisitions

3 units

An exploration of tax-free mergers and intercompany restructurings, with an emphasis on the application to business transactions. Class is lecture and problem-based and involves close analysis of the Internal Revenue Code and Treasury Regulations. The course will also have a required writing component. This writing component will generally include drafting an analysis of the tax consequences of an acquisition transaction. The course will specifically address tax principles applicable to (i) taxable acquisitions, (ii) reorganizations under Section 368(a) of the Internal Revenue Code, and (iii) single party reorganizations. [Any Non-Tax LL.M. student interested in taking this course must receive special permission, and will receive a letter grade, which will not calculate into their JD GPA.]