Cross-Border Acquisitions: Structuring Acquisitions, Section 7874 Inversion Rules, Section 338(g) Elections, GRAs
Recording of a 110-minute CPE webinar with Q&A
This webinar will discuss tax consequences of cross-border transactions. Our knowledgeable panel of foreign planning professionals will discuss outbound transfers, foreign acquisitions and section 338(g) elections, and section 7874 inversion transaction.
Outline
- Cross-border acquisitions: introduction
- Sections 367(a) and 367(b)
- Incorporation of a foreign branch
- Asset reorganizations
- Indirect stock transfers
- Transfer of intangible property
- Gain recognition agreements
- Foreign acquisition/ dispositions:
- General reorganization provisions for foreign acquisitions
- Taxable acquisitions/ dispositions
- Section 338(g) Elections
- Inversion rules: Section 7874
Benefits
The panel will review these and other critical issues:
- Sections 367(a) and 367(b)
- Section 7874 inversion rules and practical considerations
- Structuring a tax-free acquisition of a foreign company
- How to make a Section 338(g) election and when it is most beneficial
- Utilizing GRAs (gain recognition agreements) to defer tax
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.
Alexis M. Maguina
Attorney
Fenwick & West
Mr. Maguina focuses his practice on a broad range of domestic and international tax matters, such as mergers and... | Read More
Mr. Maguina focuses his practice on a broad range of domestic and international tax matters, such as mergers and acquisitions, corporate restructurings, private equity funds and tax controversies.
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William R. Skinner
Partner
Fenwick & West
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and... | Read More
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and international corporate transactions. He has broad experience in international tax issues for U.S. corporations, foreign corporations, and high net-worth individuals, and has represented clients across a variety of industries. He teaches international taxation as an adjunct professor in San Jose State University’s MST program, and speaks and writes frequently on international and corporate tax issues.
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