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.