U.S. Tax Treatment of Hybrid Entities and Transactions: Sections 267A and 245A(e) Regulations
Navigating the Mismatches of U.S. and Foreign Tax Law, Key Planning Techniques for Tax Professionals
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will discuss U.S. tax law anti-hybrid rules and restrictions that may apply where U.S. and foreign tax law provide different characterizations of transaction or entity, including regulations under Section 267A and Section 245A(e).
Outline
- Overview of reasons for new rules
- Overview of anti-hybrid regulations under Sec. 267A and Sec. 245A
- Impact of the new regulations
Benefits
The panel will review these and other key issues:
- What are the key provisions of recent IRS regulations for hybrid entities and transactions?
- What are the key tax considerations impacting international tax planning?
- What are hybrid deduction accounts and how do they impact a taxpayer’s dividends-received deduction under section 245A?
- What taxpayer relief is provided under the final regulations?
Faculty
Devon M. Bodoh
Partner
Weil Gotshal & Manges
Mr. Bodoh advises clients on cross-border mergers, acquisitions, inversions, spin-offs, other divisive strategies,... | Read More
Mr. Bodoh advises clients on cross-border mergers, acquisitions, inversions, spin-offs, other divisive strategies, restructurings, bankruptcy and non-bankruptcy workouts, the use of net operating losses, foreign tax credits, deficits and other tax attributes, and consolidated return matters.
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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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Amanda P. Varma
Partner
Steptoe & Johnson
Ms. Varma advises multinational businesses, family offices, and high-net-worth individuals on US federal income tax... | Read More
Ms. Varma advises multinational businesses, family offices, and high-net-worth individuals on US federal income tax matters, with particular focus on international tax planning and controversies. She counsels both US- and foreign-owned businesses across a variety of industries, regularly advising on the US tax consequences of cross-border investments, reorganizations, business restructurings, acquisitions, and financings.
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