Double Taxation

Blog Author Makes Appearance in Taxes Magazine; Though Regrettably, Not the Swimsuit Issue

Blog Author Makes Appearance in Taxes Magazine; Though Regrettably, Not the Swimsuit Issue

Do you love flowcharts?

Orendless citations?

How about reading through variousactions involvingP and S?

/says the last part fast and giggles like a school girl

If that sounds like you, then you may enjoy this article I recently had published in the September issue of Taxes Magazine, titled “Identifying Reverse Acquisitions and the Resulting Tax Consequences”.

The reverse acquisition rules of Treas. Reg. 1.1502-75(d)(3) are among the most complicated rules within THE most complicated area of tax law: the consolidated return regulations.Unfortunately, many tax advisors don’t realize a reverse acquisition has occurred until it’s too late, and as a result, the wrong tax returns are filed for the wrong periods, creating a mess that can take significant time and effort to unwind.

In this article, I establish five tests tax advisors can employ to determine whether a reverse acquisition has occurred, and then go on to discuss the resultingtax consequencesof a reverse acquisition. I hope you enjoy; it’s got all the P and S you can handle.

/can’t stop giggling

Click here for a PDF of the article: Identifying Reverse Acquisitions and the Resulting Tax Consequences

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