Corporate Tax Developments: Tariffs and M&A, Relation Back Doctrine, Recent PLRs
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will cover recent tax developments and the issues they create for U.S. and global companies. Our panel of international tax professionals will discuss the effect of tariffs on M&A, the origin of claim doctrine, and recent private letter rulings (PLRs), along with steps that businesses need to take in light of these developments.
Outline
- Corporate tax developments: introduction
- Tariffs and M&A
- Relation back doctrine
- Original of claim doctrine
- Recent corporate private letter rulings
- IRS Memo on Section 245A(a) to dividends
- Other developments
Benefits
The panel will review these and other critical issues:
- The impact of current tariffs on mergers and acquisitions
- IRS stance on the dividend received deduction for CFCs
- Recent PLRs that affect businesses
- Steps practitioners and companies need to take considering recent corporate tax developments
Faculty
Surbhi Bordia
Partner
Armanino Advisory
Ms. Bordia has over 15 years of extensive public accounting experience on addressing various complex transaction tax... | Read More
Ms. Bordia has over 15 years of extensive public accounting experience on addressing various complex transaction tax and international tax issues. She has assisted several clients on transaction tax related matters including but not limited to taxable and non-taxable U.S. and cross-border reorganizations, liquidations, redemptions, spin-offs, dispositions, debt restructurings, due diligence projects and in application of consolidated return regulations. Ms. Bordia has hands on experience in international tax restructuring, IP migration planning, legal entity rationalizations and integrations post mergers and acquisitions. Her areas of expertise include but is not limited to GILTI, BEAT, FDII, anti-hybrid rules, foreign tax credit, subpart F, withholding tax, investment in US property, FX gains and losses, treaty related issues, outbound transfers, permanent establishment and profit attribution rules etc. Before joining Armanino, Ms. Bordia worked at PwC, KPMG and Deloitte. She received her MBA at Haas School of Business at UC Berkeley, International Tax Certificate from Golden Gate University, Masters in Business and Bachelor of Commerce from Jai Narain Vyas University, India.
Vikram Sharma
Attorney, Senior Manager, National Tax Office
Armanino Advisory
Mr. Sharma is a Senior Manager at the National Tax Office of M&A at Armanino. He consults private equity,... | Read More
Mr. Sharma is a Senior Manager at the National Tax Office of M&A at Armanino. He consults private equity, growth equity and strategic corporate clients in navigating complex tax implications of mergers and acquisitions transactions. Mr. Sharma's experience encompasses advising on tax structures for various M&A transactions including leveraged buyouts, secondary buyouts, institutional buyouts, spin-offs, corporate reorganizations, conversions, and the utilization of net operating losses. He also provides strategic guidance on the tax aspects of forming of private equity funds, joint ventures, SPACs, refinancings, distressed sale of assets and bankruptcy reorganizations. Mr. Sharma is also an attorney admitted in New York and India.
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Pierre Yapo
Senior Manager, National Tax Office
Armanino Advisory
Mr. Yapo a Senior Manager in the National Tax Office (Mergers and Acquisitions) of Armanino Advisory LLC.... | Read More
Mr. Yapo a Senior Manager in the National Tax Office (Mergers and Acquisitions) of Armanino Advisory LLC. He advises both private equity investors and strategic corporate buyers and sellers on all matters of income and non-income tax structuring, tax due diligence, and tax modelling of domestic and cross-border inbound (foreign to US) and outbound (US to foreign) transactions. Mr. Yapo completed his graduate studies (Master of Science in Accountancy - tax concentration) at the University of Notre Dame, and his undergraduate studies (Bachelor of Science - accounting), with honors (cum laude), at Illinois State University.
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