Description
Focuses on the international tax implications under Section 367 and its impact on inbound and outbound transactions.
Designed For
- Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.
Objectives
- Interpret when and how Section 367(b) alters the application of the general reorganization non-recognition tax rules of Section 332, 351, 355, and 368
- Assess whether a reorganization or restructuring may qualify as an "inversion" subject to the rules of Section 7874
- Evaluate the considerations of making a Section 338 election in a cross-border transaction
- Evaluate whether a related party stock sale could give rise to dividend income due to the application of Section 304
Highlights
- Section 351
- Section 332
- Section 367
- Gain recognition agreements
- E&P inclusion