This course examines the tax consequences of various forms of taxable as well as nontaxable mergers and acquisitions. Building upon the distribution and liquidation regime covered in TAX 110, it considers the Section 338 election in the context of practical merger and acquisition planning. Tax-free reorganizations are examined in some detail, including the tax consequences to the parties and circumstances in which one or another type of reorganization may be appropriate. The course will introduce students to intragroup sales subject to Section 304 and the closely related.

This course complements and goes beyond TAX 110 Federal Income Tax: Corporate. A substantive/statutory course that deals with law, theory, and policy in the context of the U.S. Tax Code.

Open to Tax LL.M. students.

Recommended for the Following Professional Pathways: Corporate Transactions and Governance; Tax

Prerequisites: Federal Income Tax: Individual, and Federal Income Tax: Corporate

2 Credits