Tax Issues in Multinational M&A: Choice of Entity, Section 338(g) Election, GILTI vs. Subpart F
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will outline the caveats international tax professionals need to be aware of when working with buyers and sellers of multinational entities. Our panel of experts will explain the latest tax considerations of business combinations for multinational companies after the recent tax act.
Outline
- Cross board M&A: an overview
- Subpart F
- GILTI
- 245A regulations
- Section 338(g) election
- Tax treaties
- State tax
- Non-tax considerations
Benefits
The panel will review these and other important issues:
- When a buyer should make a Section 338(g) election
- When being subject to GILTI may result in less tax liability
- What considerations are there in choosing an appropriate entity structure?
- When is the 245A dividend received deduction available?
Faculty
Pamela A. Fuller, Esq.
Of Counsel (Tax, M&A, International)
Tully Rinckey
Ms. Fuller’s practice has a triple focus: tax planning, tax controversies, and tax compliance. She advises a wide... | Read More
Ms. Fuller’s practice has a triple focus: tax planning, tax controversies, and tax compliance. She advises a wide range of clients–including private and public companies, joint ventures, funds, high-net-worth individuals, C-Suite executives, and government entities–on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. Ms. Fuller advises clients on both purely domestic transactions and transnational ones, helping both U.S.-based companies and foreign companies (and their executives) achieve the best possible results from a tax and business perspective. Ms. Fuller is Chair of the ABA’s Tax Section’s Tax Policy Committee, and also Co-Chair of the International Tax Committee of the ABA’s worldwide International Law Section. She frequently speaks at law conferences, and publishes papers on international tax topics in peer-reviewed law journals.
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Robert Hallman
Director
CLA
Mr. Hallman has over a decade of international tax experience including roles in Big 4, middle-market and industry. His... | Read More
Mr. Hallman has over a decade of international tax experience including roles in Big 4, middle-market and industry. His specialties include both inbound and outbound legal entity restructuring, mergers and acquisitions, and treasury management, with a particular emphasis on Subchapters C and K in a cross-border context and financial reporting for income taxes.
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