Cross-Border Acquisitions: Structuring Acquisitions, Section 7874 Inversion Rules, Section 338(g) Elections, GRAs
Recording of a 110-minute CPE webinar with Q&A
This webinar will discuss tax consequences of cross-border transactions. Our knowledgeable panel of foreign planning professionals will discuss outbound transfers, foreign acquisitions and section 338(g) elections, and section 7874 inversion transaction.
Outline
- Cross-border acquisitions: introduction
- Sections 367(a) and 367(b)
- Incorporation of a foreign branch
- Asset reorganizations
- Indirect stock transfers
- Transfer of intangible property
- Gain recognition agreements
- Foreign acquisition/ dispositions:
- General reorganization provisions for foreign acquisitions
- Taxable acquisitions/ dispositions
- Section 338(g) Elections
- Inversion rules: Section 7874
Benefits
The panel will review these and other critical issues:
- Sections 367(a) and 367(b)
- Section 7874 inversion rules and practical considerations
- Structuring a tax-free acquisition of a foreign company
- How to make a Section 338(g) election and when it is most beneficial
- Utilizing GRAs (gain recognition agreements) to defer tax
Faculty
Surbhi Bordia
Partner
Armanino
Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact... | Read More
Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact international companies’ operations and puts tax efficient structures in place for her clients. Ms. Bordia’s hands-on experience in international tax, IP migration planning and legal entity rationalizations make her an expert consultant and key team player for clients in mergers and acquisitions. Ms. Bordia’s focus areas include GILTI, BEAT, FDII, anti-hybrid rules, foreign tax credits, subpart F, withholding tax, investments in U.S. property, FX gains and losses, treaty-related issues, outbound transfers and permanent establishment and profit attribution rules.
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Alexis M. Maguina
Attorney
Fenwick & West
Mr. Maguina focuses his practice on a broad range of domestic and international tax matters, such as mergers and... | Read More
Mr. Maguina focuses his practice on a broad range of domestic and international tax matters, such as mergers and acquisitions, corporate restructurings, private equity funds and tax controversies.
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William R. Skinner
Partner
Fenwick & West
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and... | Read More
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and international corporate transactions. He has broad experience in international tax issues for U.S. corporations, foreign corporations, and high net-worth individuals, and has represented clients across a variety of industries. He teaches international taxation as an adjunct professor in San Jose State University’s MST program, and speaks and writes frequently on international and corporate tax issues.
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