Peter Faber, will be presenting on 'State and Local Tax Issues in Corporate M&A Transactions.' This panel will discuss state and local tax issues that arise in corporate transactions with particular emphasis on IRC Section 338(h)(10) sales and tax-free reorganizations and spin-offs; potential pitfalls and planning opportunities will be discussed.
Lowell Yoder will be presenting on 'The Government Speaks on the Recently Issued Section 385 Regulations.' This panel will discuss the new Section 385 regulations regarding debt/equity classification. Lowell will also present on 'Cross-Border Mergers, Post-Acquisition Integration and Other International Issues'. This panel will discuss mergers with US parent companies; mergers with foreign parent companies; exchangeable share structures; use of hybrids; debt/equity developments, including recently issued Section 385 regulations; inversion transactions, including recently issued Section 7874 regulations; regulations under Section 367(a)(5); transfers of intangibles; issues under Section 367(b); maximizing use of foreign cash; Section 304 transactions; post-acquisition integration; reporting and withholding obligations; IRS Business Plan topics.
ABOUT THE EVENT
This three-day program will focus on the tax issues presented by the entire spectrum of modern major corporate transactions, from relatively simple 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. Evolving techniques for structuring, financing, and refinancing corporate turnovers and other activities will be emphasized, with particular attention being paid to consolidated return issues, to financially troubled businesses, to the role of new financial products and the effects of the evolving economic substance and business purpose doctrine, and to selected current issues in mergers and acquisitions, including the effects of the recently issued Section 385 and Section 7874 regulations.