Outbound Transactions and U.S. Federal Tax

Tackling Compliance Challenges for U.S. Companies With Foreign-Based Income or Business Relationships

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, January 15, 2013

Recorded event now available

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Course Materials

This teleconference will give corporate tax professionals and advisors a review of essential federal tax issues affecting outbound transactions and explore difficult aspects that frequently arise in preparing related IRS forms.


Tax specialists must stay abreast of complex and evolving IRS regulations affecting outbound transactions (investments by U.S. companies, or their business relationships, in foreign countries), in order to handle compliance challenges arising with IRS forms such as 5471, 926, 8865 and 8895, among others.

To properly navigate forms preparation on outbound transactions, tax professionals often will need to turn to IRS rules such as Sect. 351 on controlled foreign corporations, Sect. 367(a) and (b) on CFC restructurings, and Sect. 7874 on anti-inversion — as well as tax treaties and check-the-box rules.

A review of the key governing concepts from federal regulation, and a discussion of the more problematic aspects of related IRS forms, will prepare you to handle tax compliance on outbound transactions confidently and completely, as U.S. companies' international ties proliferate.

Listen as our panel of tax advisors reviews the most important principles of U.S. taxation of outbound transactions in a practical context to meet the toughest challenges in preparing related IRS forms.



  1. Overview of key concepts
    1. Worldwide income and foreign tax credits
    2. Entity structures
    3. CFCs and Subpart F
    4. Re-organizations and asset transfers
    5. Anti-inversion rules
    6. Tax treaties
  2. Issues to anticipate U.S. forms and schedules
    1. Form 5471
    2. Form 926
    3. Form 8865
    4. Form 8895
    5. Others


The panel will address these and other topics that have a material impact on outbound transactions forms compliance:

  • Tax implications of choice of entity and check-the-box regulations for U.S.-owned foreign companies.
  • The "control" standard for foreign entity ownership.
  • Controlled foreign corporation restructuring and the tax impact of asset transfers outside the U.S.

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Christopher Karachale
Christopher Karachale

Senior Counsel

He works with business and individual clients on a broad range of tax planning and controversy engagements, including...  |  Read More

Melinda Fellner Bramwit
Melinda Fellner Bramwit

Norris McLaughlin & Marcus

Ms. Bramwit's practice emphasizes federal, state and international tax planning and transactions, particularly in...  |  Read More

Vinay Navani
Vinay Navani

Wilkin & Guttenplan

He works primarily with high-tech, software and other closely held businesses on U.S. taxation of international...  |  Read More

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