Reorganizations

Accounting Rules in Corporate Reorgs. Simplified

The IRS issued final regulations (T.D. 9534) intended to clarify and simplify rules concerning continuity of accounting methods and inventory methods in certain tax-free corporate reorganizations and liquidations.

Final Regs. Issued on Killer B Transactions

The IRS has issued final regulations to close a loophole (known as Killer B transactions) that allowed one or more foreign corporations involved in a triangular reorganization to repatriate earnings tax free to the United States in certain circumstances.

New "Killer B" Regulations Issued

The IRS has issued new final regulations on cross-border reverse triangular reorganizations, popularly known as “Killer B” transactions.

A Trap for the Unwary in the COI Regs.

Vagueness about how long the stock of the acquiring corporation had to be retained after the acquisition led to a significant change to the continuity of interest regulations in 1998, which eliminated the requirement that the stock of the acquiring corporation be retained post-acquisition.

Final Basis Regs. Provide Deferral Opportunities in Tax-Free Exchanges

Co-Editors: Michael Metz, CPA; Nick Gruidl, CPA, MBT Final regulations addressing basis and boot in reorganizations provide interesting and unexpected results. Secs. 358 and 356 address allocation of basis to property received in a reorganization and gain recognition on receipt of boot, respectively. Proposed regulations (REG-116564-03, 5/3/04) provided a tracing

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Tax software survey

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NEWS

Congress enacts tax reform

Here are many of the most important provisions in the new law that affect both individual taxpayers and businesses. All changes were effective Jan. 1, 2018, except as noted.