The corporate form holds a considerable amount of assets in the US economy, for
example, according to the IRS Statistics of Income, total assets reported for
active corporations was in excess of $88 trillion for the 2013 tax year.
Thus, the dollar value of corporate reorganizations, and
any result in tax consequences, can be substantial.
For this reason, tax law often dictates the type or
form of reorganization carried out by a corporation.
In this module,
you will learn about different types of tax deferred reorganizations.
Specifically, in the first lesson, you will review the so-called confusing legacy
of IRS rulings and court decisions that shape the tax rules of today.
The next lesson examines sections 368, which defines seven types of corporate
reorganizations that received non-recognition treatment, and
five principles that underlie these definitions.
From here you will learn more about the tax treatment of a reorganization,
which is similar to the treatment of like kind exchanges.
Along the way, you will examine real world reorganizations
undertaken by well known corporations.
As always, when relevant, you will apply these concepts to Sunchaser Shakery.
Note that this area of taxation is extremely dense and complex, thus
the overarching goal of this module is to familiarize you with the basic principles.