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Section 338(h)(10) Election: An In-Depth Guide for M&A Tax Planning
A Section 338(h)(10) election is a nuanced and powerful provision within the Internal Revenue Code, designed to provide flexibility in the tax treatment of certain corporate acquisitions.
Evan Howard
May 12, 20257 min read


What is a Type D Tax-Free Reorganization?
A Type D tax-free reorganization is a corporate restructuring mechanism under the U.S. Internal Revenue Code (IRC) that allows businesses to transfer assets between corporations without triggering immediate tax consequences.
Evan Howard
Apr 23, 20255 min read


The Great Corporate Migration: Why Companies Are Fleeing Delaware’s Courts
DEXIT showing to be a possible exodus of US corporations from the once business friendly State of Delaware.
Evan Howard
Apr 21, 20255 min read


Google and Standard Oil: Antitrust Echoes Across a Century
The world of antitrust law has come full circle. Over a century after the landmark breakup of Standard Oil, the United States government is again in court with a corporate giant—this time, Google.
Evan Howard
Apr 19, 20257 min read


Type C Tax-Free Reorganization: Comprehensive Overview
Allowing one corporation to acquire substantially all the assets of another corporation in exchange for voting stock - tax-free treatment
Evan Howard
Apr 6, 20254 min read


Understanding Type B Tax-Free Reorganizations: Structure, Rules, and Benefits
Type B Tax-Free Reorganization - a stock for stock swap with no tax implications
Evan Howard
Apr 5, 20255 min read
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