Review options for structuring the sale of a business, from both buyer’s and seller’s perspectives with the aim of minimizing tax cost.
Attendees will consider the sale of C corps, S corps and partnerships. This course covers topics not routinely considered in a tax compliance practice, but important to the sale of a business.
Recognize tax planning opportunities for selling a business.
Identify the tax consequences of using employment and consulting agreements, covenants not to compete, personal goodwill and contingent sales price.
Recall how to treat acquired intangibles (IRC 197).
Identify the basics of Section 754 and Section 338 elections.
Determine how to best transfer ownership to employees.
Taxable asset sales, sale of stock of corporation and stock redemptions
Comparison of tax consequences of C corps, S corps and partnerships
Tax treatment of transaction costs of acquired intangibles, IRC 197
Seller consulting and employment agreements
Employee stock ownership plan
Tax deferred acquisitive corporate reorganizations
Net operating losses and tax credits of acquired corporate business
Sec. 1202; Stock Section 1244; the basics of stock Section 754 elections; and Sec. 338 and 338(h)(10) elections
CPAs, financial professionals and attorneys.
An understanding of the taxation of individual, corporations, S corps and partnerships.