Totino, Salvatore J.
Acquiring the equity of an entity taxed as an S corporation? consider an "F Reorg" / Salvatore J. Totino
Resumen.
Although would-be buyers in middle market M&A transactions continue to face challenges in what generally remains a seller’s market, there are sometimes opportunities to take advantage of an often-overlooked planning method that can offer tax and non-tax benefits for both buyers and sellers. A significant number of target companies in the middle market are organized as S corporations, and a buyer’s strategic use of an “F reorganization” in an M&A transaction involving an S corporation can generate substantial tax benefits for the buyer and, in some cases, more flexibility for the seller. Despite a decidedly non-glamorous name, the “F reorganization” can be a powerful tool in a buyer’s M&A toolkit that should not be ignored.
SOCIEDADES
OPERACIONES SOCIETARIAS
CONCENTRACION
REESTRUCTURACIÓN DE EMPRESAS
IMPUESTOS
PLANIFICACION FISCAL
GASTOS FISCALES
ESTADOS UNIDOS
Journal of Taxation of Investments 0747-9115 v. 40, n. 2, Winter 2023, p. 57-60
Acquiring the equity of an entity taxed as an S corporation? consider an "F Reorg" / Salvatore J. Totino
Resumen.
Although would-be buyers in middle market M&A transactions continue to face challenges in what generally remains a seller’s market, there are sometimes opportunities to take advantage of an often-overlooked planning method that can offer tax and non-tax benefits for both buyers and sellers. A significant number of target companies in the middle market are organized as S corporations, and a buyer’s strategic use of an “F reorganization” in an M&A transaction involving an S corporation can generate substantial tax benefits for the buyer and, in some cases, more flexibility for the seller. Despite a decidedly non-glamorous name, the “F reorganization” can be a powerful tool in a buyer’s M&A toolkit that should not be ignored.
SOCIEDADES
OPERACIONES SOCIETARIAS
CONCENTRACION
REESTRUCTURACIÓN DE EMPRESAS
IMPUESTOS
PLANIFICACION FISCAL
GASTOS FISCALES
ESTADOS UNIDOS
Journal of Taxation of Investments 0747-9115 v. 40, n. 2, Winter 2023, p. 57-60