In the current environment, companies across industries are making – or thinking ahead to – strategic acquisitions, dispositions and restructurings. When senior executives propose these types of business deals, the senior tax executive is responsible for helping them achieve their objectives in the least costly way.

This means developing structures that reduce both the costs and risks associated with the deals. Sometimes such structures, or methodologies, are not widely understood – certainly by the general public and sometimes even by the very tax executives who are charged with this important responsibility.

Among the many issues tax executives face in this regard are the following:

Opportunities and problems on a go-forward basis – Companies that are considering major transactions need assurances that the consequences will be palatable from a tax perspective.

Opportunities and problems for already completed deals – Companies being examined by the IRS for a specific transaction need to be able to support the positions reflected on their returns.

Transaction costs – After deals are closed, companies need to know what portion of the costs may be deducted and what costs they are obliged to capitalize and potentially recover through amortization. This involves documentation, timing and nature of costs, among many other issues.

Compliance with new tax shelter regulation –The IRS and many states are scrutinizing these transactions at a level of granularity that has not been seen in many years. Keeping up and complying with the new regulations is difficult for even the best-equipped tax department.

Troubled companies and restructuring – Executives of financially distressed companies need to know how to use net operating losses, liquidations of insolvent subsidiaries or other types of restructurings to their greatest advantage.

Shareholder pressure –In the current environment, companies are being compelled to demonstrate shareholder value, which may involve a corporate restructuring. Avoiding double taxation both at the corporate level and the shareholder level is a critical element of this process. Often this involves soliciting private letter rulings from the IRS. Yet today the IRS is less receptive to certain requests. The risks are high.

Consider Deloitte Tax LLP when you face these or other issues that can impact your company’s objectives and strategies. Professionals in our Sub C practice offer experience that can only be gained by administering relevant areas of law for the United States Government. In fact, many of our professionals did that for decades in their previous positions, which included IRS group and branch chiefs, associate chief counsels, docket attorneys and many others.

Our team members also build eminence through numerous speaking engagements, teaching in prominent law schools and writing for publications. Some have even been cited by the Supreme Court in connection with the resolution of cases at that level.

If you need help putting the pieces together in a meaningful way – such that your transactions are most tax efficient and fit within your company’s risk profile – look to the Sub C professionals at Deloitte Tax.