Tax Mergers and Acquisitions
Protecting and maximizing your deal
Whether you are buying or selling, tax issues can complicate every deal. Finding a transaction structure that meets the needs of the buyer and the seller, achieving a step-up in tax basis, and determining whether and how net operating losses, carryforwards and other tax attributes can be utilized are complex issues that need to be addressed.
RSM’s mergers and acquisitions tax professionals understand transactions. We’ve worked on thousands of transactions for large public companies, S corporations, partnerships, family-owned businesses and entrepreneurs. We work with companies across a wide range of industries and with diverse strategies and goals. Our professionals know the issues and the solutions.
Because understanding taxes isn’t enough, we won’t rest until we understand your business, your goals, the reasons behind your strategy and your transaction. Only then can we tailor a solution to the tax issues surrounding your transaction that is right for you.
That’s the power of RSM—the Power of Being Understood.
IRS removes business purpose and device from section 355 no-rule list, allowing taxpayers to gain certainty on section 355 distributions.
FINANCIAL INSTITUTIONS INSIGHTS
Advance tax planning can maximize shareholder value and help avoid any tax pitfalls or unnecessary marks to your purchase price.
Tax Court decision upholds IRS reclassification of intercompany debt as equity and denies taxpayer interest deductions.
IRS provides safe harbors for unwinding prespin recapitalizations allowing qualification of a section 355 spin-off.
Regulations would address the ‘hot dog stand’ issue by restricting tax-free spin-offs that rely upon a relatively small ATB.
Chief counsel advice memorandum disallows 70 percent safe harbor on success based fees in deemed asset sale transaction.