Law 249 - Tax Aspects of Mergers & Acquisitions
Steven A. Bank
J.D. University of Chicago, 1994
This course surveys the taxation of reorganizations and other adjustments involving continuing businesses, including mergers, asset and stock acquisitions and other similar shifts of ownership and control, recapitalizations, and divisions, with an emphasis on transactions eligible for nonrecognition treatment under the Code. Points of focus may include the recognition of gain and loss and the survival and allocation of tax attributes (basis, earnings, and loss carryovers) in these transactions. Our objective will be to gain a conceptual understanding of the tax treatment of reorganizations and to begin a practical introduction to the tax planning of such business transactions. Taxation of Business Enterprises is NOT a prerequisite; instead, we will review the basic principles and mechanics of corporate taxation in the first few classes so that everyone is on the same footing going forward.