IRC Section 367 Outbound Transfers of Assets: Identifying Transactions, Reporting Requirements and Exceptions
Recording of a 110-minute CPE webinar with Q&A
This webinar will discuss the U.S. tax consequences of outbound asset transfers to foreign corporations. Our panel of international tax experts will explain the interplay of Section 367 with the nonrecognition rules, reporting responsibilities, and gain recognition agreements (GRAs) with the IRS for taxpayers who have made or are contemplating overseas transfers of assets.
Outline
- IRC Section 367: introduction
- Qualifying transactions
- Types of assets
- Gain recognition agreements
- Final and proposed downward attribution regulations
- Section 6038B reporting requirements
- Strategies to avoid Section 367
- Remedies for untimely or incomplete filings
Benefits
The panel will cover these and other critical issues:
- Common transactions that trigger gain recognition under Section 367
- Handling untimely and incomplete filings of Form 926
- The interplay of Section 367 with nonrecognition rules
- Filing a GRA with the IRS
Faculty
Anthony V. Diosdi
Partner
Diosdi & Liu
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax... | Read More
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.
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Irina Pisareva
Partner
Crowell & Moring
Ms. Pisareva is a partner in the New York office of Crowell & Moring. She has 25 years of experience advising... | Read More
Ms. Pisareva is a partner in the New York office of Crowell & Moring. She has 25 years of experience advising businesses and investors on transaction tax and cross-border tax matters. Ms. Pisareva's most recent practice focused on providing tax advice to investment funds, corporations, tax-exempt investors, venture capital and private equity groups and high net worth individuals and family offices. She also advises clients on tax compliance and tax operational issues relevant to cross-border investments, credit and distressed debt transactions, global securities trading and mobile workforce. Ms. Pisareva is a frequent contributor on these topics and has been quoted in Law360 and Bloomberg Law.
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