M&A Tax Planning Strategies for S Corporations
Asset vs. Stock Sales, 338(h)(10) and 336(e) Elections, Built-In Gains Tax, and More
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax professionals guidance on tax challenges in S corporation mergers and acquisitions and available tax planning techniques. The panel will discuss key legal and tax considerations for both buyers and sellers, the pros and cons of asset sales versus stock sales, qualifying for installment sales treatment as an S corporation, built-in gains tax, and taxation of the shareholders. The panel will also discuss 338(h)(10) and 336(e) elections and other critical tax issues that need to be accounted for to achieve the most beneficial tax outcome.
Outline
- Asset purchases and sales
- Stock purchases and sales
- F reorganizations
- Various transaction alternatives
- Shareholder distributions
Benefits
The panel will cover these and other critical issues:
- Pre-sale F reorganizations
- Avoiding built-in gains tax on sales
- When an election under 338(h)(10) would result in significant tax savings
- The differences between 338(h)(10) and 3336(e) elections
- How shareholders are taxed on dispositions
Faculty
Caroline Banzali, JD, LLM
Attorney
Banzali Law
Ms. Banzali is an independent M&A Transaction Tax Attorney and Strategic Business Consultant specializing in... | Read More
Ms. Banzali is an independent M&A Transaction Tax Attorney and Strategic Business Consultant specializing in operational and legal entity structuring, pre-transaction readiness, tax due diligence and risk mitigation, transaction modeling, IRC Sec. 1202 analyses, post-transaction integration and tax optimization planning for businesses, founders, and stakeholders, as well as general legal services. Her extensive Accounting, Finance, Tax and Legal experience as Executive as well as Trusted Advisor, have culminated in her unique arsenal of commercial business savvy coupled with Tax technical and Legal expertise. After over 25 years in practice, Ms. Banzali emerged from "retirement" to build several middle-market M&A Transaction Tax practices, before finally establishing her own full-service Legal Practice in Beverly Hills, California. Her industry expertise includes media and entertainment, licensing and merchandising, technology and emerging growth industries, consumer products, healthcare, health and wellness, real estate and hospitality, professional services, and automotive.
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