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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 will we tailor a solution to the tax issues surrounding your transaction that is right for you.
In PLR 201930011, the Service rules that it is OK to “go your own way” without tax penalty in a textbook split-up.
Sellers are able to command top dollar if they go into the sales process ready to hit the ground running which includes tax preparation.
Taxpayer must use the year-by-year method in determining NOL carryover due to section 170 adjustments to modified taxable income.
IRS allows early reconsolidation given waiver of capital loss generated by the disaffiliation and lack of other tax benefits.
Active trade or business present in subsidiary without independent current revenue but with a plan to make future product sales.