Section 338(h)(10) Election – The Unicorn of M&A

Section 338(h)(10) Election – The Unicorn of M&A

Perhaps you’re the owner of a medium-large corporation and you’re looking to buy a smaller corporation or even a unicorn. And by unicorn, I don’t mean the mythical beast, but rather the mythical startup. Today we’ll talk about another kind of unicorn, one entirely...
The How To Guide to M&A: Shareholder Loans

The How To Guide to M&A: Shareholder Loans

This article will provide a brief overview of what a shareholder loan is, and the difference between equity and debt as two types of loans. Next, the tax consequences to corporations of shareholders’ interest on loans will be discussed. The last section will mention a...
Reverse Triangular Merger: The Taxable and Tax-Free Version

Reverse Triangular Merger: The Taxable and Tax-Free Version

This article will introduce the two variations of the reverse triangular merger: the taxable version (commonly reversed to as the reverse triangular cash merger) and the tax-free version.  We will also discuss the tax considerations that accompany these two types of...