International Taxable Acquisitions and Dispositions

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.