Prerequisites: RCC*; Tax I (LAW 607); Tax II (LAW 697). This course focuses primarily on the Federal income tax consequences of corporate ownership reorganizations. It explores corporate combinations, including taxable and tax-free mergers and acquisitions, corporate divisions (spin-offs, split-offs, and split-ups), as well as rearrangements of the capital structure of a single corporation, such as through recapitalizations and stock dividends. It also explores the carryover of tax attributes after corporate combinations