Reorganizations and Consolidated Tax Returns for a company

Reorganizations and Consolidated Tax Returns for a company

This is an assignment that discusses the Reorganizations and Consolidated Tax Returns for a company. The paper also compares the long term tax benefits.

Reorganizations and Consolidated Tax Returns for a company

Firstly, 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 also 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.

Additionally, use the Internet and Strayer Library to research the rules and income tax laws regarding Types A, B, C, and D reorganizations and consolidated tax returns. Be sure to also use the six (6) step tax research process in Chapter 1 that was demonstrated in Appendix A of your textbook as a guide for your written response.

Questions

1.      Firstly, compare the long-term tax benefits and advantages of each type of reorganization and recommend the type of reorganization that will be most beneficial to the client.
2.      Secondly, suggest the type of reorganization the client should use for the ABC Corporation based on your research. Justify the response.
3.      Thirdly, propose a taxable acquisition structure for the client’s planned acquisitions over a nontaxable reorganization. Assess the value of a taxable transaction over a nontaxable reorganization for the client.

4.      Examine the value and limitations of including the ABC Corporation if acquired as a wholly owned subsidiary in the consolidated return and provide a recommendation to your client. Then, support the recommendation with applicable research.
5.      Create a scenario that will allow the client to reduce any disadvantages from filing a consolidated return as a member of a controlled group.
6.      Lastly, use the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Assignment requirements

Your assignment must follow these formatting requirements:

Type, double space, using Times New Roman font (size 12), with one-inch margins on all sides; citations and references must follow APA or school-specific format. Also, check with your professor for any additional instructions.
Include a cover page containing the title of the assignment, the student’s name, the professor’s name, the course title, and the date.

The specific course learning outcomes associated with this assignment are:
Analyze and research tax issues regarding corporations, partnerships, S corporations, and consolidated tax returns.
Create client, internal, and administrative documents that appropriately convey the results of tax research and planning.
Subsequently, create an approach to tax research that results in credible and current resources.

Grading for this assignment will be based on answer quality, logic / organization of the paper, and language and writing skills, using the following rubric.