U.S. Tax Treatment of Hybrid Entities and Transactions: Sections 267A and 245A(e) Regulations
Navigating the Mismatches of U.S. and Foreign Tax Law, Key Planning Techniques for Tax Professionals
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will discuss U.S. tax law anti-hybrid rules and restrictions that may apply where U.S. and foreign tax law provide different characterizations of transaction or entity, including regulations under Section 267A and Section 245A(e).
- Overview of reasons for new rules
- Overview of anti-hybrid regulations under Sec. 267A and Sec. 245A
- Impact of the new regulations
The panel will review these and other key issues:
- What are the key provisions of recent IRS regulations for hybrid entities and transactions?
- What are the key tax considerations impacting international tax planning?
- What are hybrid deduction accounts and how do they impact a taxpayer’s dividends-received deduction under section 245A?
- What taxpayer relief is provided under the final regulations?
Amanda P. Varma
Steptoe & Johnson
Ms. Varma advises multinational businesses, family offices, and high-net-worth individuals on US federal income tax... | Read More
Ms. Varma advises multinational businesses, family offices, and high-net-worth individuals on US federal income tax matters, with particular focus on international tax planning and controversies. She counsels both US- and foreign-owned businesses across a variety of industries, regularly advising on the US tax consequences of cross-border investments, reorganizations, business restructurings, acquisitions, and financings.Close
to be announced.
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