International Tax Transactions I

Overview

Putting corporate reorganizations, liquidations, and stock acquisitions in an international context.

Highlights

Key Topics

• Reorganizations and liquidations under Section 367(b)
• Stock acquisitions (including Section 338)
• Inversion rules under Section 7874
• Related party stock sales

Prerequisites

None

Designed For

Who Will Benefit

Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.

Objectives

Learning Outcomes

• Identify whether a reorganization or restructuring may qualify as an "inversion" subject to the rules of Section 7874.
• Recognize the implications of making a Section 338 election in an acquisition of foreign corporate stock from a third party.