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Restructuring Tax Services
Bringing clarity to uncertain situations
In times of economic uncertainty, debt restructuring is oftentimes a necessary and even beneficial option that can preserve and enhance a company’s value. However, the unique scenarios brought on through refinancing or modifying debt obligations have significant and sometimes unique tax consequences.
RSM’s mergers and acquisitions tax professionals help you give careful consideration to debt restructuring or bankruptcy filing and can guide you through what can be a difficult process. We understand the complexities of working through a bankruptcy or debt restructuring and can help you achieve the most tax-advantageous outcome for your situation.
Our professionals can also help with other types of corporate transactions including the determination of the taxability of corporate dividends.
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.
IRS: The “share-by-share approach” to recovery of stock basis, although broadly appropriate, might not apply to every scenario.