Assignment 3: Reorganizations and Consolidated Tax Returns
Suppose you are a CPA, and you have a corporate client that has been operating for several years. The company is considering expansion through reorganizations. The company currently has two (2) subsidiaries acquired through Type B reorganizations. The client has asked you for tax advice on the benefit of a Type A, C, or D reorganization over a Type B reorganization. Additional facts regarding the issues are reflected below.
- The company currently files a consolidated income tax return with the two (2) subsidiaries acquired through a Type B reorganization.
- ABC Corporation, a subsidiary targeted by the client for takeover, has substantial net operating losses.
- XYZ Corporation and BB Corporation will be acquired as subsidiaries in the next six (6) months.