As the 2023 calendar year-end approaches, companies should start thinking about transactions that may have occurred during the year and the impact of those transactions on the 2023 tax provision as well as related compliance requirements. There are also items to keep in mind to assist in efficient tax planning for what 2024 may bring.
Please join professionals from the KPMG M&A Tax and State and Local Tax practices, as well as the Washington National Tax office, as they discuss:
- Distributions, including the determination of what portion of a distribution is treated as a dividend versus return of capital versus capital gain for U.S. federal as well as state income tax purposes.
- Potential limitations on the ability to utilize tax attributes, including the Ownership Change rules under Section 382 and the rules under Section 384, which limit the use of preacquisition losses to offset built-in gains.
- Section 174 R&D capitalization and its impact on taxable income, and the utilization of tax attributes.
- The new corporate alternative minimum tax (“CAMT”) “change in ownership” and the relationship to an “ownership change” under Section 382.
- Common tax considerations that arise in the context of a stock disposition as well as some of the more complex rules that may require further analysis when calculating stock basis; and the impact of the Inflation Reduction Act on 2023 and planning for 2024.