This course is updated in 2020 and reflects changes made by the 2017 Tax Cuts & Jobs Act and IRS regulations interpreting rules prescribed by that Act. The course focuses on critical US tax considerations affecting taxable acquisitions and dispositions involving foreign target companies or operations. We start with a brief overview of key US tax rules that affect buyers and sellers, including regimes introduced by the Tax Cuts and Jobs Act of 2017 and recent regulations interpreting those new rules. We then describe how these rules apply in common fact patterns. Finally, we describe considerations important to buyers and sellers. This course is ideal for tax and financial professionals that wish to develop or refresh expertise in the international transactional tax area. It is also useful for investors, CFOs and other finance professionals who don’t typically deal with international M&A transactions but need to become familiar with important rules and negotiating considerations affecting the area.

Learning Objectives
  • Identify common M&A transaction structures and when they are typically used.
  • Understand critical US tax considerations affecting taxable M&A transactions involving foreign target companies or operations.
  • Learn how key US tax provisions apply to common taxable transaction fact patterns.
  • Understand potential pitfalls, negotiation points, and other considerations that apply to various types of M&A transactions.
  • Discover changes under the 2017 Tax Act that fundamentally affect international M&A deals.
Last updated/reviewed: March 16, 2024
6 Reviews (33 ratings)


Member's Profile
I really liked that this course highlighted the interests of the buyer and seller when considering section 1248 and 338 elections. This made the audience truly understand the mechanics of these sections and give a practical knowledge for using the knowledge obtained in the real world. I wish more courses were setup like this course.

Anonymous Author
There was a lot of information covered in this course- but the slides were a bit confusing and could have used more time to cover items in greater depth.

Anonymous Author
Excellent coverage of a very complex topic. Great examples.

Member's Profile
Good job on covering a LOT of information. Thank you!

Anonymous Author
good but powerpoint not comprehensive.

Member's Profile

Course Complexity: Advanced

Fundamental knowledge of common tax, business and legal terms. (Finance and accounting professionals with some tax background would generally have this knowledge.)

Education Provider Information
Company: Illumeo, Inc., 75 East Santa Clara St., Suite 1215, San Jose, CA 95113
Contact: For more information regarding this course, including complaint and cancellation policies, please contact our offices at (408) 400- 3993 or send an e-mail to .
Instructor for this course
Course Syllabus
  Before and After TCJA8:03
  TCJA Impacts9:09
  TCJA Territorial System10:24
  TCJA Rules/Regimes-GILTI7:24
Section 1248
  Section 1248: Overview8:01
  Section 1248: Provisions8:30
Section 338
  Section 338: Overview 5:23
  Section 338: Election in International Setting 10:08
  Section 338: Consistency Rules 6:31
Common Patterns
  Common Fact Patterns 10:00
  First Tier Foreign Target 5:26
  Lower Tier Foreign Target 5:16
  Other Considerations & Course Summary 12:48
Continuous Play
  International Taxable Acquisitions and Dispositions1:51:51
  Slides: International Taxable Acquisitions and DispositionsPDF
  International Taxable Acquisitions and Dispositions Glossary IndexPDF