Focuses on the international tax implications under Section 367 and its impact on inbound and outbound 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
Section 351;Section 332;Section 367;Gain recognition agreements;E&P inclusion
