Gain a better understanding of the requirements of an F reorganization.
Final regulations promulgated by Treasury and the IRS in 2015 provide a comprehensive set of rules regarding 'F' reorganizations. This topic will examine those regulations in detail, including the requirements to qualify as an 'F' reorganization, the impact of related redemptions and distributions, the application of the step transaction doctrine, and overlap rules with respect to other reorganizations under section 368. The material will provide examples that illustrate the operation of the rules in the regulations and discuss transaction planning considerations with regard to 'F' reorganizations.
Agenda
Faculty
Andrew F. Gordon
Steptoe LLP
- Of counsel with Steptoe & Johnson LLP
- Practices in all areas of federal income taxation, with a focus on planning and transactional matters
- Experience advising clients on domestic and international acquisitions, mergers, joint ventures, restructurings, and spin-off transactions
- Experienced in handling audit and tax controversy matters, he has represented clients in examinations and in all stages of the Internal Revenue Service administrative process; his experience also includes litigation in Tax Court
- Advised clients on matters of tax policy, including corporate and international tax reform and energy-related government incentives
- Drafted position papers and comment letters on proposed legislation and administrative guidance, and has met with Treasury and the Internal Revenue Service on such topics
- J.D. degree, magna cum laude, University of Florida; LL.M. degree in taxation, New York University School of Law; B.B.A. degree, cum laude, University of Miami
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