Tax Accounting in Mergers and Acquisitions, 2008CCH, 2007 - 70 pages |
Contents
Chapter | 1-4 |
COSTS INCURRED IN HOSTILE TAKEOVERS | 1-5 |
Chapter | 1-10 |
Chapter | 1-11 |
Treatment of Contingent Liabilities | 1-21 |
107 TRIANGULAR A REORGANIZATIONS 145 | 1-45 |
ASSETSFORSTOCK OR C REORGANIZATIONS 153 | 1-53 |
111 RECAPITALIZATIONS OR E REORGANIZATIONS 159 | 1-59 |
602 AMOUNTS PAID OR INCURRED TO ACQUIRE OR CREATE | 6-6 |
113 BANKRUPTCY OR G REORGANIZATIONS 162 | 6-62 |
including tax considerations The most basic tax issue is whether to structure | 6-94 |
101 ¹Taxable stock acquisitions are discussed at 102 1 below | 6-101 |
EFFECTIVE DATE AND METHOD CHANGE ISSUES 6127 | 6-127 |
CONSEQUENCES OF A SIGNIFICANT MODIFICATION 712 | 7-12 |
802 CONTINGENT PAYMENT OBLIGATIONS | 8-8 |
DEBT ISSUED WITH PROPERTY RIGHTS 817 | 8-17 |
Chapter 1 | 2-1 |
Chapter 2 | 2-2 |
1101 METHOD OF ACCOUNTING FOR CONSOLIDATED GROUP | 2-11 |
CODE 461h 223 | 2-23 |
Accounting | 3-3 |
Chapter 6 | 3-6 |
STOCK PURCHASE 314 | 3-14 |
TREATMENT OF PURCHASER OF ASSETS OR STOCK | 3-23 |
305 CODE 351 TRANSACTION 329 | 3-29 |
Chapter 8 | 3-31 |
307 DUE DILIGENCE 363 | 3-63 |
Illustration | 3-79 |
Chapter 1 | 4-1 |
INTRODUCTION | 4-4 |
Chapter 9 | 4-9 |
CODE 1060 410 | 4-10 |
405 CODE 351 TRANSFERS 437 | 4-38 |
CONTINGENT LIABILITIES UNDER CODE 381 444 | 4-44 |
204 CLEAR REFLECTION 241 | 5-1 |
Chapter 11 | 5-11 |
SHAREHOLDER COSTS 542 | 5-42 |
512 STOCK ISSUANCE COSTS 547 | 5-48 |
Accounting for Restructuring Transactions under Sections 351 | 8-21 |
APPLICABLE HIGHYIELD DISCOUNT OBLIGATIONS | 8-25 |
CODE 163j 828 | 8-28 |
DISQUALIFIED DEBT INSTRUMENTS PAYABLE | 8-38 |
| 8-45 | |
OVERVIEW OF SECTION 197 | 8-46 |
CATEGORIES OF SECTION 197 INTANGIBLES 921 | 17 |
EFFECTIVE DATE 934 | 30 |
Limitation on Loss CarrybacksCorporate Equity Reduction | 10-1 |
301 OVERVIEW | 10-2 |
1003 CORPORATE EQUITY REDUCTION INTEREST LOSS 1022 | 10-22 |
THE AVOIDED COST METHOD 1030 | 10-30 |
1103 INTERCOMPANY TRANSACTIONS IN INVENTORY 1145 | 11-45 |
1104 INTERCOMPANY SUBVENTION TRANSACTIONS 1159 | 11-60 |
1105 SEVERAL LIABILITY FOR CONSOLIDATED TAX 1166 | 11-66 |
Table of Internal Revenue Code Sections | 1 |
Table of Treasury Regulations | 7 |
Table of Cases T15 | 15 |
Table of Statutes T21 | 21 |
| 1 | |
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Common terms and phrases
9th Cir accounting method accrual method acquiring corporation adjustment agreement amortization amount realized amounts paid apply asset acquisition assumed basis bright line rule buyer capital carryback cash CERT COBE Commissioner consent consolidated group consolidated return contingent liabilities contract Corp corporation's costs incurred debt instrument deductible under Code deemed determined distribution election engagement letter entity events test example exchange expenditures fair market value fees FIFO final regulations gain or loss INDOPCO intangible asset interest expense IRS Letter Ruling LIFO method ment merger method change method of accounting NCNB Newco noted partnership party payment principal method prior Proc provides pursuant qualify recognize gain recurring item exception reorganization respect result seller shareholders specifically Square D stock acquisition subsidiary taken into account target corporation Tax Court taxpayer tion trade or business transaction costs transfer transferor treated treatment widgets