Course: Proposed Rule on Profits and Related Basis Adjustments based on this document from the Federal Register: https://www.govinfo.gov/content/pkg/FR-2024-12-02/pdf/2024-27227.pdf This document contains proposed regulations regarding previously taxed earnings and...
Corporate Separations and Reorganizations Under Proposed IRS Regulations
This course provides an in-depth look at the IRS’s proposed regulations affecting corporate separations, incorporations, and reorganizations. Gain insights into distributions of controlled corporation stock, liability assumptions, and property exchanges between corporations. Learn how these regulations impact corporations, shareholders, and security holders, ensuring compliance and strategic tax planning in corporate transactions.
In this course you will learn the following:
* Understand the purpose and scope of the proposed regulations.
* Understand the impact of the proposed regulations on corporate separations, incorporations, and reorganizations.
* Identify key definitions and operative rules related to these transactions.
* Understand the requirements for nonrecognition of gain or loss in these transactions, including distributions of stock and securities, assumptions of liabilities, and exchanges of property.
* Recognize the importance of the “plan of reorganization” and “plan of distribution” concepts.
* Understand the implications of post-distribution payments and debt replacement.
* Be aware of the proposed applicability dates and the effect on existing revenue rulings.
Additional information
| Federal Register Title | Guidance Regarding Certain Matters Relating to Nonrecognition of Gain or Loss in Corporate Separations, Incorporations, and Reorganizations. Document Number: 2025-00321 |
|---|---|
| Course SKU | FR-25-553-1 |
| Why This Course Is Important | Without this course, you might miss critical insights into compliance with IRS proposed regulations, risking non-compliance and inefficient tax planning for corporate transactions. |