Tax Issues in Inbound and Outbound Transactions: Utilizing Partnerships to Maximize Tax Benefits
Avoiding Landmines Under Current Tax Law, Deal Structures, Special Allocations
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will guide tax counsel and professionals on tax challenges and opportunities in utilizing partnerships for inbound and outbound transactions. The panelist will discuss key provisions impacting inbound and outbound transactions under current U.S. tax law, effectively using partnerships in structuring deals to maximize tax benefits and avoid unintended tax consequences, key considerations in using U.S. versus foreign partnerships, special allocations, and other items to ensure tax savings.
Outline
- Key provisions impacting inbound and outbound transactions under current U.S. tax law
- Utilizing partnerships in deal structures to maximize tax benefits
- U.S. versus foreign partnerships: understanding the implications and liability of inbound and outbound transactions
- Special allocations: rules and techniques for sellers and purchasers
- Key tax aspects of the acquisition agreements: reps, warranties, covenants, indemnities
Benefits
The panelist will discuss these and other key issues:
- Critical provisions of current U.S. tax law impacting inbound and outbound transactions
- Effectively using partnerships in inbound and outbound transactions to ensure tax benefits
- Structuring the deal and understanding the differences and potential traps for foreign and U.S. partnerships
- Understanding special allocation rules and concepts to revise deal structures for tax savings under U.S. tax law
- Key tax aspects of acquisition agreements and drafting tips to avoid tax pitfalls
Faculty
Ulises Ruiz, JD, LLM
Principal
Prager Metis CPAs
Mr. Ruiz is the Principal-In-Charge for the International Tax Department of Prager Metis, a member of Prager Metis... | Read More
Mr. Ruiz is the Principal-In-Charge for the International Tax Department of Prager Metis, a member of Prager Metis International Group. He has more than 25 years of experience in the accounting industry and has earned his Juris Doctorate and LLM degree.
Mr. Ruiz has over twenty years of experience specifically in international tax niche with a specialization in tax advisory, tax planning, structuring and compliance. He represents high-net-worth clients, manufacturing and distribution companies, public companies, real estate clients, and technology-based companies.
His area of expertise lies in helping companies and individuals with cross-border tax issues alongside providing advisory functions to help optimize tax profile of international business.
Mr. Ruiz is a noted industry expert and has been a prolific speaker and author on topics pertaining to international taxation. He has participated by providing his valuable insights in articles like Bloomberg’s BNA tax management portfolios, foreign income-based transfer pricing on rules and practice in selected countries and more.
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