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Course Details

This CLE/CPE course will offer tax and corporate professionals practical guidance on structuring leveraged buyouts and tax-efficient strategies for debt acquisition financing. The panel will discuss the use of debt finance in structuring asset and stock purchase transactions and mergers, and detail the tax implications of various debt structures to obtain the best possible tax treatment of a debt-financed buyout.

Description

An acquisition or merger funded all or in part with a material amount of debt continues to serve as a valuable option for companies’ growth strategy. Navigating the array of factors to consider while structuring leveraged buyouts requires in-depth knowledge of pitfalls to avoid and securing the tax benefits of substituting debt for equity.

Recognizing available debt options and the tax implications of a leveraged structure such as interest deductions for indebtedness, characterization of debt and equity, and stepped-up vs. carryover basis, will assist in advising both buyers and sellers.

Listen as our experienced panel provides guidance in assessing transactions to aid the process of structuring leverage buyouts along with the tax implications of Section 279, Section 338(h)(10), Section 336(e) and Section 163 in debt-financed acquisition transactions.

Outline

  1. Debt options for leveraged buyouts
  2. Multi-layer debt and equity financing
  3. Deducting interest and characterization of debt and equity (Section 279 and Section 163).
  4. Allocation of basis in a taxable asset or stock purchase (Section 338(h)(10) or 336(e) elections)

Benefits

The panel will review these and other key issues:

  • Identifying the mechanics of a properly structured leveraged buyout
  • Recognizing the benefits and drawbacks of using multi-layer debt and equity financing structures
  • Determining interest deductibility and proper characterization of debt and equity in various structures
  • Discerning the different treatments of stepped-up vs. carryover basis and related tax implications

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Ascertain various debt options for financing leveraged buyouts
  • Identify the pros and cons of multi-layer debt and equity financing
  • Determine the proper characterization of debt and equity and the affect on the deductibility of interest
  • Recognize the affect of Section 338(h)(10) and Section 336(e) elections

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Working knowledge of partnership/corporate structure, debt financing, merger, and liquidation.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.