Coverage Examples
- IRC Section 355 tax-free spinoffs
- Tax-free reorganization qualification
- S corporation status and 338(h)(10) basis step-up elections
- Validity of historic NOLs under IRC Section 382 change of ownership rules
- Survival of NOLs post Chapter-11 restructuring under IRC Section 382(l)(5)
- Cancellation of debt in context of restructurings
- Valuation risks tied to restructurings
- Successor liability risk
- Debt/Equity characterization
- Cross-border withholding uncertainties (including treaty qualification and portfolio interest)
- REIT/RIC compliance history
- BEAT safe harbor computations
- GILTI and Subpart F exclusions
- Pillar 2 planning (including transitional safe harbor considerations)
- Transfer pricing risks
- Trade or Business / ECI risks for loan funds
- REIT status and dealer property risks
- Qualification as a domestically controlled REIT
- “End of Life” risks (closing out lingering tax exposure to allow fund wind up)
- Worthless stock / abandonment losses
- IRC Section 1202 small business stock capital gain exclusion
- Capital/Ordinary income characterization
- IRC Section 409A deferred compensation risks
- Tax residency and tax treaty qualification risks
- Estate and gift tax planning (including valuation risks)
- Recapture risk
- Transferability risk
- Structural risk
- Qualified basis risk
- Prevailing Wage and Apprenticeship compliance
- Bonus adder eligibility: domestic content, energy community, low-income community
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