Random Facts Flashcards
What tax related anti-takeover defense could Disney have used to send off comcast’s takeover attempt?
Disney could have threatened to spin off highly appreciated (low basis) assets an used the spin-off as a tax poison pill
How did paired REITs provide tax benefits?
They allowed for the management of real estate while avoiding double tax on the c corporation that managed the real estate
What tax issue led to a court dispute prior to united airlines bankruptcy?
Section 382 and the preservation of united’s pre-bankruptcy NOLs
In the acquisition of a highly appreciated privately held entity, what technique might be used to diversify the seller while deferring income taxation?
Mixing bowl partnership
How much were the goodwill a amortization related tax deductions derived in its acquisition of time warner to AOL?
$0
If 368A was structured to be a forward triangular A, identify one additional requirement that must be met for tax free treatment?
Must acquire “substantially all” of the target’s assets
What is acquired in section 351?
Stock or assets
What are the requirements for tax free treatment with respect to proportion of stock?
Must receive at least 80% of newco’s stock
351: what type of stock
Voting, non voting, preferred and common
How much of acquirer stock in 368A?
At least 40%
What type of stock in 368A?
Common or preferred, voting, or non voting
How much were the tax benefits for P&G in Clairol transaction? What percent of the deal were the tax benefits?
$1bn
20%
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Extension of NOL carryback period from 2 to 5 years allowed for refund of previously paid taxes.
Reverse triangular 368a stock percentage
80%
What kind of stock in reverse triangular 368a?
Voting stock
