U.S. International Tax: Advanced Issues

Overview

An in-depth discussion of complex international tax matters, including cross-border formations and reorganizations, U.S. tax treaties, and more.

Highlights

Key Topics

• Transfer pricing methods
• Permanent establishment
• Formations
• Reorganizations
• Liquidations
• Inversion rules under Section 7874
• Related party stock sales
• Non-recognition transactions

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 the accepted transfer pricing methods and recognize when each is appropriate to use.
• Recognize the base erosion and profit shifting (BEPS) initiatives and their relationship to U.S. and global transfer pricing.
• Identify when a PE exists.
• Identify the tax consequences of an exit event, such as liquidation, related-party sale, and third-party sale (with availability of certain elections).
• Recognize the implications of making a Section 338 election in an acquisition of foreign corporate stock from a third party.
• Recognize whether an outbound liquidation qualifies for non-recognition treatment under IRC Section 332.
• Identify when IRC Section 367 alters the application of the general non-recognition tax rules of IRC Sections 351 and 332.