An examples-based discussion of key concepts, including effectively connected income, branch profits tax (BPT), branch-level interest tax, Form 1120-F, and more.
Learning 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.
