International Tax Transactions II

Overview

Build a solid foundation.

This self-study online course is part of the U.S. International Tax Certificate, a comprehensive learning program geared to help global finance and accounting professionals navigate the highly complex world of international taxation. This course can be purchased individually or as part of the U.S. International Tax: Advanced Issues bundle. You must purchase the bundle to earn the digital badge.

The CPE self-study course focuses on the international tax implications under Section 367 in Sections 351 and 332 transactions (outbound/inbound) including:

• the need for Gain Recognition Agreements
• calculation of the all Earnings and Profits (E&P) inclusion
• impact from Section 367(d).

Highlights

Key Topics

• Section 351
• Section 332
• Section 367
• Gain recognition agreements
• E&P inclusion

Prerequisites

None

Designed For

Who Will Benefit

• Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.

Objectives

Learning Outcomes

• Interpret when and how Section 367(b) alters the application of the general reorganization non-recognition tax rules of Section 332, 351, 355, and 368
• Assess whether a reorganization or restructuring may qualify as an "inversion" subject to the rules of Section 7874
• Evaluate the considerations of making a Section 338 election in a cross-border transaction
• Evaluate whether a related party stock sale could give rise to dividend income due to the application of Section 304