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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: November 08, 2020

3 Reviews (22 ratings)Reviews

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

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 .
Course Syllabus
INTRODUCTION AND OVERVIEW
  8:03Before and After TCJA
  9:09TCJA Impacts
  10:24TCJA Territorial System
  7:24TCJA Rules/Regimes-GILTI
Section 1248
  8:01Section 1248: Overview
  8:30Section 1248: Provisions
Section 338
  5:23Section 338: Overview
  10:08Section 338: Election in International Setting
  6:31Section 338: Consistency Rules
Common Patterns
  10:00Common Fact Patterns
  5:26First Tier Foreign Target
  5:16Lower Tier Foreign Target
CONCLUSION
  12:48Other Considerations & Course Summary
Continuous Play
  1:51:51International Taxable Acquisitions and Dispositions
SUPPORTING MATERIALS
  PDFSlides: International Taxable Acquisitions and Dispositions
  PDFInternational Taxable Acquisitions and Dispositions Glossary Index
REVIEW & TEST
  quizREVIEW QUESTIONS
 examFINAL EXAM