Taxation of Mergers and Reorganizations (3 credits)

A practical introduction to the federal (and, to a lesser extent, state) tax treatment of select corporate transactions. We will examine the statutory and common-law requirements for tax-free mergers, asset and stock acquisitions, and recapitalizations, as well as for tax-free "divisive" reorganizations, including spin-offs and split-ups. Naturally, we will also give some attention to the consequences of failure to qualify for tax-free treatment, as well. Prerequisites: Taxation I. Corporate Tax is recommended, but we will review the handful of concepts from that course necessary to a thorough understanding of this one. Grading will be by exam and optional problem sets. Prerequisites: Taxation I