Focuses on the international tax implications cross-border Sections 367 and and inversion transactions.
Learning 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
Major Topics
Reorganizations;Stock acquisitions;Inversion rules under Section 7874;Related party stock sales
