Jasper Cummings, Jr. served as a panelist for the session "Current Issues in Tax-Free and Partially Tax-Free Acquisitive Reorganizations" on November 7 at 9:30 a.m., during this seminar coordinated by the Praticsing Law Institute (PLI). The session covered recent use of tax-free and partially tax-free strategies; observations concerning structuring reorganizations in a world without General Utilities; current issues in the reorganization area and illustrative case studies; multi-step reorganizations and effects of recent revenue rulings; downstream mergers and group inversions; issues involving control and continuity; effects of COBE and COI regulations; fluctuations in value of acquirer stock and the signing date rule; reorganizations within a consolidated group; overlap transactions; up/down transactions; down/up transactions; Yoc Heating developments; the “substantially all” requirement; the Bausch & Lomb regulations; triangular reorganization basis regulations; “no net value” regulations; “all cash” D reorganizations; developments in “F” reorganizations; loss importation and duplication; proposed regulations regarding basis recovery and determination; avoiding reorganization treatment; remnants of liquidation - reincorporation doctrine; movement of attributes; allocation of E&P; legislative changes and IRS Business Plan topics.
November 6-8, 2012
Sofitel Chicago Water Tower/ Chicago, IL
November 6-8, 2012
Sofitel Chicago Water Tower/ Chicago, IL