Advanced Corporation Tax: Spin-Offs and Single Party Reorganizations

2 units

An exploration of tax-free mergers, spin-offs, and intercompany restructurings, as well as an introduction to consolidated groups, 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 specifically address (i) tax principles applicable to reorganizations under Section 368(a) and Section 355, (ii) acquisitive and single party reorganizations, (iii) spin-off and divisive reorganizations, and (iv) principles applicable to consolidated groups provided in the regulations under Section 1502. [JD students interested in taking this course must receive special permission, and will receive a letter grade, which will not calculate into their JD GPA.] Note: This course will focus on SPIN-OFFS AND SINGLE PARTY REORGANIZATIONS . TAX FREE MERGERS AND ACQUISITIONS is the focus of an Advanced Corporate Tax course offered in fall 2013.