lllll ap ingrate Cor ter i Acquisitions a Reorganization在s
1 Chapter 7: Corporate Acquisitions and Reorganizations
CORP ACQUISITIONS REORGANIZATIONS (1 of 2) Taxable acquisition transactions Taxable vs tax-free acquisitions Tax consequences of reorganizations Acquisitive reorganizations Devisive reorganizations
2 CORP ACQUISITIONS & REORGANIZATIONS (1 of 2) Taxable acquisition transactions Taxable vs. tax-free acquisitions Tax consequences of reorganizations Acquisitive reorganizations Devisive reorganizations
CORP ACQUISITIONS REORGANIZATIONS (2 of 2) Other reorganization transactions Judicial restrictions on reorganizations Tax attributes Limitation on use of tax attributes Example 3
3 CORP ACQUISITIONS & REORGANIZATIONS (2 of 2) Other reorganization transactions Judicial restrictions on reorganizations Tax attributes Limitation on use of tax attributes Example
Taxable Acquisition Transactions Asset acquisitions Stock acquisitions w/ no liquidation Stock acquisitions w/ liquidation Stock acquisitions w/ deemed liquidation
4 Taxable Acquisition Transactions Asset acquisitions Stock acquisitions w/ no liquidation Stock acquisitions w/ liquidation Stock acquisitions w/ deemed liquidation
Asset Acquisitions Direct purchase of assets Target corporation Gain or loss and depreciation recapture are computed by selling corporation on each asset Acquiring corporation Basis in assets is acquisition cost 5
5 Asset Acquisitions Direct purchase of assets Target corporation –Gain or loss and depreciation recapture are computed by selling corporation on each asset Acquiring corporation –Basis in assets is acquisition cost