Reference no: EM132350480
I Develop and diagram an approach for Axle and Cooke to consider, in executing Cooke's acquisition (develop & diagram the best alternative). Other advisors will focus on the legal and financial aspects of implementing your plans, which should take into account both current and future tax liabilities. For this purpose, consider federal tax consequences only. Your design and diagrams should consider Type A, B and C reorganizations.
II Provide a summary of the high level tax considerations that will result from a carrying-out of your plans (a type A, B or C reorganization). Include citations to controlling tax law. Your comments should focus on the following:
A. Common Requirements
1. Plan of Reorganization
2. Business Purpose
3. Continuity of Shareholder Interest (COSI)
4. Continuity of Business Enterprise (COBE)
B. Effect on the Corporation
C. Effect on the Shareholder
D. Carryover of Tax Attributes
Attachment:- Corporation reorganization - Axle case study.zip
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