Leveraging Outbound Transfers of Corporate Stock and Other Property
Navigating Sect. 367 Gain Recognition Agreements and Sect. 6038B Regs in Cross-Border Transactions
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide guidance to counsel on the use of outbound transfers and the recently issued IRS rules impacting those transfers. The panel will discuss gain recognition agreement requirements and the reporting rules and offer best practices for leveraging outbound transfers.
- Transactions that fall under IRC §367
- IRS final rules (Nov. 2014)
- Considerations for avoiding GRAs
- Best practices for leveraging outbound transfers and minimizing taxes
The panel will review these and other key issues:
- When should a company file a GRA as part of an outbound transfer? When should they avoid filing a GRA?
- How do the final regulations impact outbound transfers and GRAs?
- What are the reporting requirements for outbound transfers? How did the final regulations change these requirements?
Jon Van Loo
Mr. Van Loo focuses his practice on international and domestic tax aspects of distressed debt restructuring and... | Read More
Mr. Van Loo focuses his practice on international and domestic tax aspects of distressed debt restructuring and exchanges, investment funds, cross-border mergers and acquisitions, securities offerings, earn-outs and advising on various federal and international tax issues related to legal settlements. He represents U.S. and non-U.S. investors, funds, financial institutions, high net worth individuals and businesses.Close
Mr. Williams has experience in a wide range of federal income tax matters, including domestic and international... | Read More
Mr. Williams has experience in a wide range of federal income tax matters, including domestic and international mergers, acquisitions and dispositions; public and private financings; and both cross-border and general strategic tax planning. He also provides counsel in connection with international tax matters, including matters implicating subpart F provisions and tax treaties and international audit/tax controversy matters.Close