The column will appear in Tax Notes and Tax Notes Today and will analyze ambiguities, opportunities, and pitfalls in cross-border acquisitions, internal restructurings, and dispositions.
Gartner’s inaugural column, “Changing Your Mind With Check-the-Box,” is coauthored by Neha Prabhakar, a senior associate in the mergers and acquisitions group of PricewaterhouseCoopers LLP’s National Tax Services practice. The column explores the ability of taxpayers to use a check-the-box election to change the tax treatment of a prior stock transfer into that of a reorganization under section 368(a)(1)(D).
“Although the check-the-box election causes a deemed liquidation of the target corporation shortly after the time the stock of the target corporation is transferred,” the authors write, “it does not create an intent to liquidate the target corporation at the time of that stock transfer.”
Gartner’s practice focuses on cross-border transactions, including taxable and tax-deferred acquisitions, integration of acquired entities, internal group restructurings, joint ventures, and dispositions. He also teaches international mergers and acquisitions at the University of Washington School of Law’s LLM Tax Program. Gartner received his LLM in tax from New York University School of Law, his JD from the University of Washington School of Law, and his BA from the University of Puget Sound.
The full column is available here.
For more information or to schedule an interview, please contact Shaima Cardillo at 703-531-4852 or firstname.lastname@example.org.
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