“Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know,” Tax Strategies for Corporate Acquisitions, Dispositions,[...]

This three-day program will focus on the tax issues presented by the entire spectrum of modern major corporate transactions, from single-buyer acquisitions of a division or subsidiary to multi-party joint ventures, cross-border mergers, and complex acquisitions of public companies with domestic and foreign operations, including spin-offs and other dispositions of unwanted operations.

Tax Strategies 2024 will be the most comprehensive and insightful conference you could possibly attend on corporate tax. You will receive the very latest information, strategies and practical insights available from leading tax practitioners from law firms, accounting firms, corporations and academia from across the United States, along with policymakers from the IRS and the Department of the Treasury.

What You Will Learn

After completing this program, participants will be able to:

• Identify key risk allocation issues when negotiating and drafting provisions in acquisition agreements
• Evaluate the relative merits of taxable transactions versus tax-free reorganizations and spin-offs, and identify when it is best to employ one transaction over another
• Understand the recent significant changes to the IRS advance ruling guidelines for spin-offs, including IRS views regarding leveraged spin-offs and delayed distributions
• Understand the impact of the corporate alternative minimum tax ("CAMT") and the share repurchase excise tax on M&A transactions
• Leverage the tax benefits of using partnerships, and other passthrough entities, in joint ventures or as acquiring entities
• Employ tax efficient strategies in the acquisition of loss companies
• Understand the impact of evolving rules on cross-border acquisitions and restructurings
• Recognize, and learn to avoid, the ethical pitfalls you may encounter when providing tax opinions and recommending return positions

Special Features

• Attend three new sessions:
  • How Judicial Doctrines Shape Subchapter C and Transaction Planning
  • Tax Controversy Issues in M&A Transactions
  • Impact of the Corporate Alternative Minimum Tax ("CAMT") on M&A Transactions
• Explore "Interesting Transactions of the Past Year"
• Receive complimentary electronic access to PLI's number one bestseller, The Corporate Tax Practice Series: Strategies for Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings

Program Level: Overview

Intended Audience: Law firm and accounting firm professionals, in-house tax professionals and government attorneys who want to study the tax issues presented by modern major corporate transactions

Prerequisites: An interest in deepening your understanding of the tax issues presented by the entire spectrum of corporate transactions

Advanced Preparation: None