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This course focuses on critical U.S. tax considerations affecting taxable aquisitions and dispositions involving foreign target companies or operations,  it also highlights other issues that can affect participants involved in those transactions. 

We start with a breif overview of transaction structures and important non-tax considerations for buyers and sellers. Then we discuss key U.S. tax rules affecting taxable deals, and we describe how these rules apply in common fact patterns. Finally, we describe some planning and ongoing considerations common to all the fact patterns. 

This course is ideal for tax professionals and accountants that wish to develop or refresh expertise in international M&A transactions; CFOs and other finance professionals who have some familiarity with tax and wish to increase their understanding of the area will also find it helpful.

Learning Objectives

  • Identify common M&A Transaction structures and recognize when they are typically used
  • Explore critical U.S. tax considerations affecting taxable M&A transactions involving foreign companies or operations
  • Explore how key U.S. tax provisions apply to common taxable transaction fact patterns involving international operations 
  • Recognize potential pitfalls, negotiating points, and other considerations that apply to M&A transactions, particularly in an international setting.  

4 Reviews (16 ratings)Reviews

1
Anonymous Author
This course is not suited for anyone who isn't a tax professional. There is too much to go through. The concepts were not explained well and the slides do not contain enough information to assist with answering the final exam questions.
5
Anonymous Author
Excellent coverage of a very complex topic. Great examples.
4
Anonymous Author
good but powerpoint not comprehensive.
4
Member's Profile
Good

Prerequisites

Course Complexity: Advanced

Prerequisite: A basic understanding of corporate M&A transactions and U.S. outbound international tax (Including sub part F and foreign tax credits)

Advanced Preperation: None 

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 .
Course Syllabus
INTRODUCTION AND OVERVIEW
Section 1248
  10:51Section 1248: Overview
  6:30Section 1248: Planning
Section 338
  8:00Section 338: Overview
  11:09Section 338: Election in International Setting
  10:03Section 338: Consistency Rules and U.S. Seller Pitfalls
Common Patterns
  10:00Common Fact Patterns
  9:56First Tier Foreign Target
  6:13Lower Tier Foreign Target
CONCLUSION
  12:01Other Considerations & Course Summary
Continuous Play
  1:35:09International Taxable Acquisitions: Purchases and Sales Involving Offshore Operations
SUPPORTING MATERIALS
  PDFSlides: International Taxable Acquisitions
  PDFInternational Taxable Acquisitions Glossary Index
REVIEW & TEST
  quizREVIEW QUESTIONS
 examFINAL EXAM