It is necessary for tax advisors to have a firm grasp of the complex new M&A tax rules in order to properly advise clients given the dramatically altered international tax landscape introduced by the 2017 Tax Cuts & Jobs Act. In this practical webinar, you will learn about the most important recent changes in U.S. tax law affecting U.S. taxation of multinational entities and how planning cross-border transactions—especially outbound M&As—are affected.

Among other things, you will explore some of the worst tax pitfalls and hidden traps for the unwary as created by the 2017 Act. You will also receive guidance and practical strategies for harnessing the complex rules to achieve the best possible results for clients engaged in M&A deals with offshore components. You will also learn how to address the most important aspects of the myriad Treasury regulations that have been released in the last two years.

You will learn the following:

  • Buy-and-sell techniques for acquiring and disposing of foreign targets in light of the recent tax guidance from Treasury, including the 2019 final GILTI regulations;
  • Financing techniques (and traps) in light of the §163(j) regulations;
  • Using the § 338(g) election, as well as revised “check-and-sell” techniques, in the post-2017 tax environment to your client’s tax advantage;
  • Planning techniques and modeling considerations to manage and mitigate the increased tax burden of being subject to both Subpart F and GILTI from year to year;
  • GILTI and Foreign Tax Credit modeling considerations;
  • Transferring intangible property outbound after the TCJA;
  • Recent guidance affecting both outbound and inbound transfers under § 367;
  • Planning techniques to take full advantage of the Participation Exemption under §245A; and
  • New planning opportunities created by recent taxpayer-friendly regulations and tax compliance rules issued in 2019.

Upon course completion, you will be able to:

  • Identify costly tax traps in cross-border holding structures and help your client avoid them;
  • Implement practical M&A drafting techniques and best practices to prevent seriously bad tax outcomes;
  • Effectively plan into the new § 245A 100% DRD, and the mechanics of the newly proposed §245A regulations (not yet finalized);
  • Navigate newly imposed limits on “hybrid transactions” under U.S. tax law; and
  • Help client model their various tax outcomes in Crossborder M&A transactions, so as to achieve the most optimal U.S. and global tax result.

Advanced Preparation: None

Program Level: Intermediate

Field of Study: Taxes

Credit Type: Group Internet Based for the Live Program.

Faculty Member
Pamela Fuller
Royse Law

Pamela advises a wide range of clients–including private and public companies; joint ventures; “start-ups”; private equity and hedge funds; venture capital funds; real estate funds and trusts; family offices; C-Suite executives; and government entities–on transactional, investment, growth, and supply-chain strategies to achieve optimal tax and business results.
Prior to becoming an attorney, Pamela was a business reporter and all-news radio anchor for a highly regarded NBC News affiliate in her hometown of Seattle, Washington, covering geo-political and international business developments, including the emergence and growth of major multinational companies like Microsoft, Starbucks, McCaw Communications, Hewlett-Packard, Nintendo, and Boeing.

CLE Credits (Law)

Credit Value Type Format
NALA - - Credit not available
NFPA - - Credit not available
AL 1.7 General
AK 1.75 General
AR Not Available General
AZ 1.75 General
CA 1.75 General
CO 2 General
CT 1.75 General
DE 1.7 General
FL 2 General
GA 1.7 General
HI 1.75 General
IA 1.75 General
ID 1.75 General
IL 1.75 General
IN 1.7 General
KS Not Available General
KY 1.75 General
LA 1.7 General
ME 1.75 General
MN 1.50 General
MO Not Available General
MS Not Available General
MT 1.75 General
NC 1.5 General
ND 1.75 General
NE 1.66 General
NH 1.75 General
NJ 2 General
NM 1.7 General
NV 1.5 General
NY 2 General
OH 1.75 General
OK 2 General
OR 1.5 General
PA 1.5 General
RI 2 General
SC Not Available General
TN 1.66 General
TX 1.75 General
UT 1.5 General
VA Not Available General
VT 1.75 General
WA 1.75 Law and Legal Procedure
WI 2 General
WV 2 General
WY 1.75 General

In some CLE states, the course will be submitted to the bar after you register. If for any reason the course is not approved, we will fully refund your registration fee. If a state is listed on this course, then we are confident the course fits that state's standards and already is or will be approved for credit.

Accounting Credits

Credit Value Field of Study Format

Clear Law Institute is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: For more information regarding administrative policies such as complaint and refund, please see the tab above on our Money-Back Guarantee or contact us at 703-372-0550. 

CPE Credit - Maximum Credit Hours: Please see above. You must attend at least 50 minutes to obtain credit. Fields of Study: Please see above. Teaching Method: Lecture. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state’s regulatory board.

Clear Law Institute has registered with the Texas State Board of Public Accountancy as a CPE Sponsor. This registration does not constitute an endorsement by the Board as to the quality of our CPE Program.

100% of attendees recommend this webinar

4 out of 5 stars
from 2 customer reviews


5 out of 5

Daniel V.


3 out of 5

John S.

What is a webinar?

A webinar is simply a seminar that you attend online. You either watch a live video feed of the speaker or listen to the speaker through your computer, tablet or phone’s audio.  You see the speaker’s slides, videos, and other presentation materials on your screen.

Can I ask questions during the webinar?

Yes. During the live webinar, you may submit questions and comments and the speaker will respond verbally. For a recorded webinar, your questions will be emailed to the speaker. You will typically receive a response from the speaker within two business days.

Can I attend using a tablet or smartphone?

Yes. You may attend a webinar using a computer, tablet or smartphone.

If I can’t attend a webinar live, can I view the recording later?

Yes. Shortly after each live program ends, we send all webinar registrants a link to the webinar recording. You can view the recording as many times as you like after the live webinar for up to 12 months.

What is an on-demand webinar?

An on-demand webinar is a previously recorded webinar that you may view at any time after your purchase for up to 12 months.

Can I stop a recorded webinar and start it later at the same point?

You can stop a recording and later log back in and navigate to any point in the webinar. The system will not force you to view the entire recording from start to finish.

Can I listen to recorded webinars on a tablet or smartphone?

Yes. You will be able to listen to any of our on-demand webinars on your computer, tablet, or smartphone.

Do the webinars qualify for Continuing Education Credit?

Almost all of our webinars are approved for continuing education credit, including CLE (in all states), CCB, CPE, HRCI, IRS and SHRM credit.  Unlike many providers, we don’t charge you any additional fee to process your credit.  If you have specific questions, please call us at 703-372-0550 or contact us.

Can I still receive Continuing Education Credits if I view the webinar recording instead of the live presentation?

In most cases, the answer is yes. Recorded webinars are not eligible for CLE credit in the following states: AR, KS, MS, NE, and RI. In all other jurisdictions, recorded programs are eligible for credit. In addition, CPE credit is not available for recorded webinars. Please note that recorded webinars are only eligible for a certain period of time based on the jurisdiction. To ask about your specific type of Continuing Education Credit or the requirements in your jurisdiction, please call us at 703-372-0550 or contact us.

Will I receive a certificate of completion after the course?

Yes. A certificate of completion will automatically be uploaded to your Clear Law Institute account after completing the live or on-demand webinar.

Do I need to be a member to receive a certificate of completion?

No. An account will automatically be created for you when registering for a webinar. You will then be able to access your certificate of completion after completing a webinar.

How do I determine my states’s CLE requirements.

Please find your state listed here with instructions for calculating the number of credits in your state.

How will I submit my attendance to receive CLE credit in my state?

Please find your state listed here with instructions for confirming your CLE attendance.

How does the money-back guarantee work?

Clear Law Institute stands behind all of its courses with a no-risk, money-back guarantee. If you are not satisfied with the quality of a webinar, we will fully refund your money—no questions asked. If you purchase an annual all-access membership, you can cancel within 14 days for a full refund.

per person