Tax Issues in Inbound and Outbound Transactions: Utilizing Partnerships to Maximize Tax Benefits
Avoiding Landmines Under Current Tax Law, Deal Structures, Special Allocations
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This course will guide tax counsel and professionals on tax challenges and opportunities in utilizing partnerships for inbound and outbound transactions. The panel will discuss key provisions impacting inbound and outbound transactions under current U.S. tax law, effectively using partnerships in structuring deals to maximize tax benefits and avoid unintended tax consequences, key considerations in using U.S. versus foreign partnerships, special allocations, and other items to ensure tax savings.
Outline
- Key provisions impacting inbound and outbound transactions under current U.S. tax law
- Utilizing partnerships in deal structures to maximize tax benefits
- U.S. versus foreign partnerships: understanding the implications and liability of inbound and outbound transactions
- Special allocations: rules and techniques for sellers and purchasers
- Key tax aspects of the acquisition agreements: reps, warranties, covenants, indemnities
Benefits
The panel will discuss these and other key issues:
- Critical provisions of current U.S. tax law impacting inbound and outbound transactions
- Effectively using partnerships in inbound and outbound transactions to ensure tax benefits
- Structuring the deal and understanding the differences and potential traps for foreign and U.S. partnerships
- Understanding special allocation rules and concepts to revise deal structures for tax savings under U.S. tax law
- Key tax aspects of acquisition agreements and drafting tips to avoid tax pitfalls
Faculty
Morgan L. Klinzing
Attorney
Troutman Pepper Hamilton Sanders
Ms. Klinzing focuses her practice on the federal income tax aspects of U.S and international mergers and acquisitions.... | Read More
Ms. Klinzing focuses her practice on the federal income tax aspects of U.S and international mergers and acquisitions. Her experience includes advising clients on partnership formation, operations and exit issues. She works with private equity funds to coordinate cross-border tax advice for structuring investments in a tax efficient manner. In addition, she counsels clients operating as partnerships, limited liability companies and S corporations on characterization of gain in an exit.
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Thomas D. Phelan
Attorney
Troutman Pepper Hamilton Sanders
Mr. Phelan focuses his practice on tax law. He has written on tax law issues and co-authored an article with Steven... | Read More
Mr. Phelan focuses his practice on tax law. He has written on tax law issues and co-authored an article with Steven Bortnick,Planning For Qualified Dividend Income When Taking Foreign Companies Public.
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David Stauber
Partner
Troutman Pepper
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and... | Read More
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and securities offerings matters. He handles a broad range of transactions including cross-border transactions and corporate restructurings, and has considerable experience with both inbound and outbound international tax matters.
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