To ensure that tax and other financial professionals are adequately prepared to handle the challenges and potential complications that may arise during mergers and acquisitions. You will gain the knowledge to help your company and clients complete smooth transactions free of any negative consequences or disruptions.

SPEAKER:

Johnny Montoya, Partner & Tax Principal, BDO

• Tax Entity Classification
• Inside & Outside Tax Basis
• Actual Asset Purchases
• Section 338 & 336 Elections
• LLC “Drop-Down” & F Reorganization
• Disregarded Entity Mergers
• Triangular Mergers
• Stock Acquisitions & Reorganizations
• Continuity of Shareholder Interest

Johnny Montoya, Partner & Tax Principal, BDO

To ensure that tax and other financial professionals are adequately prepared to handle the challenges and potential complications that may arise during mergers and acquisitions. You will gain the knowledge to help your company and clients complete smooth transactions free of any negative consequences or disruptions.

SPEAKER:

Johnny Montoya, Partner & Tax Principal, BDO

DETAILED LEARNING OBJECTIVES

• Understand the differences between inside and outside tax basis

• Comprehend the concept of a tax “step-up”

• Recognize when a Section 338(h)(10) election is applicable

• Understand benefits of a tax step-up

• Recognize potential downsides for the seller in a tax step-up

• Identify features of an actual asset purchase

• Recognize common tax impacts of IRC Section 163(j)

• Understand the purpose of Section 336(e)

• Understand Sec 338(g) election in cross-border transactions

• Identify tax attributes in carryover vs. step-up basis

• Distinguish between stock and asset deals

• Understand the concept of GILTI (Global Intangible Low-Taxed Income)

• Recognize the requirements for tax-free Type "A" reorganizations

• Understand the continuity of business enterprise (COBE) requirement

• Identify the primary purpose of an LLC “Drop-Down” in M&A

• Tax Entity Classification
• Inside & Outside Tax Basis
• Actual Asset Purchases
• Section 338 & 336 Elections
• LLC “Drop-Down” & F Reorganization
• Disregarded Entity Mergers
• Triangular Mergers
• Stock Acquisitions & Reorganizations
• Continuity of Shareholder Interest

Johnny Montoya, Partner & Tax Principal, BDO