Self-study: Tax Attributes in Reorganization: Is There a There There?

Based on live webinar held June 17, 2020 during the AIRA AC Virtual Series.

The author Gertrude Stein was known to complain about her hometown of Oakland, California. “There is no there there,” Ms. Stein said. Perhaps the same question can be asked about tax attributes in a reorganization. Exactly how valuable are they? This program weighs the relative merits of tax attributes in restructurings, and evaluates the extent to which debtors, creditors, shareholders, and stakeholders should go to the mat to try to capture tax benefits.

Learning Objectives

After completing this program, participants will be able to:

  1. Identify tax related areas worthy of evaluation in terms of timing and structures in a bankruptcy reorganization;
  2. Understand the impact the Tax Cut and Jobs Act of 2017 on loss utilization; and
  3. Understand the interim changes to utilization rules arising under the CARES ACT of March 2020.


David Hoffman (Tax Partner, Deloitte)—David is a tax partner in Deloitte’s M&A Services practice based in Chicago. He has more than 25 years of public accounting experience, of which nearly 20 have been as a dedicated M&A tax specialist. He specializes in delivering tax consultative services related to mergers and acquisitions and other significant capital transactions, such as restructurings, dispositions, and debt workouts. He also works with his clients on transaction integration planning and execution. In connection with his work, David has developed expertise in maximizing the value of tax attributes, such as net operating losses and tax basis, as well as designing and implementing tax-efficient acquisition, financing, and exit structures.

Mark A. Cody (Partner, Jones Day)—Mark Cody has over 20 years of experience representing clients in corporate bankruptcy, restructuring, distressed situations, and other insolvency-related matters. He has advised debtors, lenders, large creditors, official creditors' committees, distressed investors, and other parties in large in-court and out-of-court corporate restructurings across the country in a variety of industries, including retail, automotive, energy, and coal. Further, he has significant experience counseling clients in distressed acquisitions, loan workouts, cross-border insolvencies, and corporate governance and fiduciary duty matters.

Robert White (Managing Director, Jefferies LLC)—Robert White has over 20 years of experience in restructuring and distressed investing. He has been a Managing Director at Jefferies for more than 10 years. Prior to Jefferies, Mr. White was a Director on Barclays Distressed Debt trading desk and a Senior Vice President in the Restructuring Group at Chanin Capital Partners. Mr. White has completed over 45 recapitalization and restructuring transactions including representing debtors, lenders, ad hoc bondholder committees, equity committees and unsecured creditor committees involving in court and out of court restructuring transactions.

Todd Maynes (Partner, Kirkland & Ellis LLP)—Todd Maynes focuses his practice on the tax aspects of debt restructurings, bankruptcy and insolvency. Todd has served as Chair of the Planning Committee for both the University of Chicago Federal Tax Conference and the Chicago-Kent College of Law Federal Tax Institute. He teaches bankruptcy taxation at Northwestern University School of Law and the Law School at the University of Chicago, previously taught advanced income taxation at Chicago-Kent College of Law, and has lectured frequently at the University of Michigan.

Price $65
CPE Credit Recommended, 1 CPE Credit hour(s), field of study—Taxes - Technical;
Knowledge level Basic—Most beneficial to CPAs and other financial advisors new to a skill or attribute, including individuals at staff or entry level in an organization as well as seasoned professionals who desire increased knowledge in the subject matter.
Additional Info Online registration and payment of fee will allow materials to sent to the participant’s email address and the participant must submit request for CPE credit after completing the requirements (instructions enclosed with materials). Presenters’ PowerPoint slides for reference are included with materials. If unable to register online, participants may call AIRA’s office at (541) 858-1665 to order.
Format Digital Materials
Prerequisites None
Advance prep None

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Requests for refunds must be received within 10 days after receipt of course subject to a $25 cancellation fee and return of all materials in good condition.

Question Resolution

For assistance regarding refunds, program cancellations, or other program related matters, please contact our offices at (541) 858-1665 or by email

National Registry of CPE Sponsors

Association of Insolvency & Restructuring Advisors (AIRA) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of Continuing Professional Education (CPE) for group training on the National Registry of CPE Sponsors.

NASBA CPE Credits are made available and awarded for AIRA group training that complies with the Statement on Standards for CPE Programs. In accordance with these Standards, relevant group training details are disclosed to learners in advance via email invitations, registration websites, or other similar advance announcements.

AIRA’s CPE Sponsor ID Numbers:

  • NASBA National Registry: 103243
  • Texas State Board of Public Accountancy: 003242

Complaints regarding NASBA National Registry CPE Sponsors may be submitted to NASBA via their website, State boards of accountancy have final authority on the acceptance of CPE Credits for Certified Public Accountants (CPAs).