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Corporate Tax Developments: Tariffs and M&A, Relation Back Doctrine, Recent PLRs

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

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Thursday, June 5, 2025

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, May 23, 2025

or call 1-800-926-7926
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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.

Description

Recent political and tax changes have significantly impacted domestic and international businesses. Tariffs imposed by the Trump administration on Canada, China, Mexico, and other countries create additional due diligence considerations for M&A transactions. Uncertainties and additional risks need to be incorporated in these combinations.

In September 2024, the IRS released CCA 202436010, stating that controlled foreign corporations (CFCs) are not entitled to the dividends received deduction under Section 245A. Corresponding regulations are anticipated.

Whether from FTC adjustments made by other countries or a decision to take a foreign tax credit rather than a deduction, foreign tax amounts are frequently redetermined. Issued in 2022, Treas. Reg. §1.905-1(d)(1)(ii) states that the FTC cannot be claimed until any disputes are resolved and a final amount determined. The IRS' interpretation of the relation back doctrine relative to this regulation can result in FTC tax changes being time-barred, subjecting taxpayers to double taxation.

In addition to the items above, numerous PLRs and cases impact MNEs, their advisers, and corporate taxpayers in general.

Listen as our panel of federal tax experts reviews recent corporate tax developments and the impact of these on domestic and international businesses.

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Outline

  1. Corporate tax developments: introduction
  2. Tariffs and M&A
  3. Relation back doctrine
  4. Original of claim doctrine
  5. Recent corporate private letter rulings
  6. IRS Memo on Section 245A(a) to dividends
  7. 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

Bordia, Surbhi
Surbhi Bordia
Partner
Armanino

Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact...  |  Read More

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Early Discount (through 05/23/25)

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