Description

The widespread use of different business forms – corporations, S Corps, LLCs and other pass-through entities – has led to the greater incidence of “inter-species” combinations. Either when clients want to rationalize various entities that have been created over time or in a formal combination of third party business, practitioners often face substantial tax and nontax uncertainty about exactly how two different species of entity are combined and with what tax effect. This program is designed as a guide to combining C Corps and S Corps with LLCs and other non-corporate forms, including discussions of entity and owner level tax treatment, non-tax considerations on the transfer of assets or ownership interests, and alternatives to formal combinations.

• Differences between corporate/corporate combinations and corporate/non-corporate mergers
• C Corp/LLC mergers and S Corp/LLC mergers
• Tax and non-tax considerations
• Asset v. equity combinations
• Entity v. owner level considerations
• Alternatives to formal combinations

About the Speaker . . .

Allen Sparkman is a partner in the Boulder, Colorado office of Sparkman Shaffer Perlick, LLP. He has practiced law for over thirty years in the areas of estate, tax, business, insurance, asset protection, and philanthropic planning matters for individuals, farmers, ranchers, businesses, and nonprofit organizations throughout the United States. Mr. Sparkman has written and lectured extensively on choice-of-entity, charitable giving and estate planning topics. He is the Colorado reporter for State Limited Partnership Laws and State Limited Liability Company Laws. (both published by Aspen Law & Business). He has also served as president of the Rocky Mountain Estate Planning Council. Mr. Sparkman received his A.B. with honors from Princeton University and his J.D. with high honors from the University of Texas.