Tax Controversy Issues in M&A Transactions

Tax attorney Lee Meyercord will participate in a Practising Law Institute (PLI) program focused on the tax issues presented by modern corporate transactions. Presenters will cover the entire transactional spectrum, from single-buyer acquisitions to multiparty joint ventures to complex mergers and acquisitions (M&A) involving foreign and domestic businesses. Lee's panel will review tax controversy issues that arise in M&A transactions, specifically how IRS enforcement activity influences corporate dealmaking and strategy. She will review recently litigated cases and administrative enforcement actions, identifying frontend issues that could wreak havoc later, facts to document and substantiate to prepare for an audit, and where the IRS is concentrating enforcement resources. Speakers will also cover what courts evaluate when cases go to litigation, providing attendees with a guide to protecting their deals from the outset and tools to draw upon if disputes arise.