Inversion Transactions: Structuring Deals to Capture Tax Benefits and Manage Post-Merger Integration
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax advisors and counsel to small and large companies with the tools to structure deals in inversion transactions that capture the tax benefits and manage post-merger integration.
- Structure of a merger inversion transaction
- Types of inversions
- IRC 7874
- Capturing the benefits of an inversion
- Limiting U.S. taxation
- Non-U.S. earnings to acquire U.S. businesses
- Base erosion techniques
- Post-merger integration and restructuring
- Future management
- Direction and geographical presence of the combined entity
- Regulatory approvals from countries involved
- Integration of the two businesses
The panel will answer the following questions:
- What are the types of inversion transactions and requirements of IRC Section 7874?
- How can an inversion transaction limit U.S. taxation, assist in the use of non-U.S. earnings to acquire U.S. businesses, and allow for base erosion techniques?
- What are the best practices for post-merger integration and restructuring?
Mr. Amon has over 30 years of experience in corporate and international taxation. He advises corporations, partnerships... | Read More
Mr. Amon has over 30 years of experience in corporate and international taxation. He advises corporations, partnerships and limited liability companies on a broad variety of business and tax matters, including mergers and acquisitions planning and consultation, restructuring planning, and international tax planning and consultation. He has extensive experience in serving clients in many industries, with an emphasis on high technology, media & entertainment, aerospace and healthcare.Close
Edward S. Wei
Cadwalader Wickersham & Taft
Mr. Wei's a transactional lawyer with significant expertise in the tax aspects of domestic and cross-border... | Read More
Mr. Wei's a transactional lawyer with significant expertise in the tax aspects of domestic and cross-border transactional matters, including taxable and tax-free mergers and acquisitions, spin-offs, bank financing arrangements, investments, partnerships and joint ventures, bankruptcy reorganizations, debt restructurings and securities issuances.Close