Corporate Reorganizations/Acquisitions

Corporate reorganizations consist of acquisitions, split-ups and spin-offs of a business, stock redemptions and recapitalizations all of which must be structured to address detailed Internal Revenue Service Regulations in order to achieve a desired tax result (i.e, usually tax deferral). Our understanding of accounting and financial issues helps us to achieve the intended economic and business results within the framework of those Regulations. In many acquisitions, our planning involves the preservation of tax attributes consisting of accounting methods and net operating losses. Occasionally, the comfort of obtaining a private letter ruling from the Internal Revenue Service is important.