Managing Corporate Tax

Overview People in this Area

Advising Clients on Complicated Tax Issues

Parsons Behle & Latimer can help you to minimize your corporate tax burdens.

Continuing the double taxation regime for closely held corporations in the era of LLCs creates inequitable burdens on older corporations and those that previously were poorly advised on tax matters. In some cases, Parsons Behle & Latimer can help. We advise clients on the purchase and sale of corporations with net operating losses, built-in gains, and built-in losses, whether the proposed transfer may constitute an ownership change under Section 382; what limitation on the use of loss would occur under Section 382 and 383; whether corporations with built-in gains can use built-in losses of other corporations to offset such gains under Section 384; whether an acquisition is made to avoid tax under Section 269; elections to use transferor’s basis in assets with diminished value by transferee corporation (asset stuffing) under Section 361(e)(2)(C); and whether the sale of certain assets makes the seller a liquidating corporation under Section 336(d)(2).