• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to secondary sidebar

Alston & Bird Tax Blog

  • Home
  • Services
  • Contacts

Check Your Timing: Tax Traps for the Unwary in Acquisition Agreements

May 17, 2021 By John Baron, Daniel Reach and Eli McCrain

Even one day of unanticipated tax liabilities can have meaningful consequences. Our Federal Tax Group turns your attention to the little-regarded – but still important – straddle-period provisions in acquisition agreements.

  • The “interim closing of the books” vs. “proration” approaches
  • Avoiding a one-day disparity between straddle-period accruals for taxes and everything else
  • Special rules for S corporation terminations

Read the full advisory here.

Filed Under: Federal Tax Advisory Tagged With: C corporation, s corp terminations, straddle period

About John Baron

John Baron leads Alston & Bird's Federal & International Tax Group and is the former chair of the firm’s Partners Committee. His practice is principally transactional in nature, and his clients include both domestic and foreign companies and financial institutions, as well as private equity firms, CDOs, and hedge funds.

[Read Bio]

About Daniel Reach

Danny Reach is an associate in the Federal and International Tax Group. His practice includes federal and international tax planning, and he has particular experience with the tax aspects of derivative financial instruments.

[Read Bio]

About Eli McCrain

Eli McCrain is an associate in the Federal & International Tax group. He focuses on transactional and international tax matters, primarily the tax consequences of domestic and cross-border mergers and acquisitions, private equity investments, private equity fund formation, restructuring transactions, and financing transactions.

[Read Bio]

Primary Sidebar

As a service of Alston & Bird’s Tax groups, this blog focuses on current issues and events in international, federal, state and local tax and wealth planning of interest to business.

Subscribe

Receive email notifications when new posts are added.

Check your inbox or spam folder to confirm your subscription.

Tags

401(k) ACA Affordable Care Act audit BEAT CARES Act CFC Corporate Tax Planning covid-19 Delaware ERISA Escheat FATCA FDII Gift cards GILTI international tax IRA IRAs IRS Kelmar New York nexus OECD qualified plans Quill RUUPA SCOTUS Section 351 Section 355 Section 367 Section 385 section 482 section 965 State legislation Subpart F Supreme Court Tax Court Tax Cuts and Jobs Act tax reform TCJA Treasury Unclaimed property UP Wayfair

Secondary Sidebar

Categories

Recent Posts

  • Litigate, Legislate and Repeat: The Delaware Escheat Law Spin Cycle
  • Looking Back at Georgia’s 2022 Legislative Session
  • Diving into IRS’s Annual Report on Advance Pricing Agreements: Can APMA Overcome Its Sisyphean Task?
  • California Dreaming of a Voluntary Compliance Program
  • Testing for COVID and Your Kits for Free: Expanded Coverage of OTC COVID-19 Test Kits and Developments in Preventive Care

Archives

Copyright © 2022 · Alston & Bird · All Rights Reserved. Privacy.