See Credit Details Below
Overview
Why You Should Attend
The changes made by the 2017 Tax Act, CARES Act, and the Inflation Reduction Act (“IRA”), and the challenging debt and equity markets have resulted in an uncertain global M&A landscape. At this year’s program, our faculty of recognized tax experts, including representatives from the Internal Revenue Service, will explore cross-border transaction structures and review tax planning considerations in today’s constantly evolving world.
What You Will Learn
After completing this program, participants will be able to:
- Identify opportunities and pitfalls when selling a non-U.S. business
- Determine when a spin-off is the best way to divest a business
- Describe the impact of the Inflation Reduction Act (“IRA”) on cross-border acquisitions
- Recognize planning opportunities in the post-acquisition integration of target and acquirer operations
Who Should Attend
This program is designed for private practitioners, in-house tax professionals and anyone seeking a deeper understanding of the tax planning considerations in structuring international M&A deals in today’s challenging market.
Special Feature: Luncheon presentation “The Wrath of Moore” exploring the potential consequences of the Supreme Court’s decision in Moore vs. United States
Program Level: Overview
Intended Audience: Law firm and accounting firm professionals, in-house tax professionals and government attorneys who want to study the tax planning considerations in structuring international M&A deals.
Prerequisites: An interest in exploring the nuances of tax planning in cross-border M&A.
Advanced Preparation: None
Lecture Topics [Total time 00:08:30]
Segments with an asterisk (*) are available only with the purchase of the entire program.
- Opening Remarks* [00:02:37]
Karen Gilbreath Sowell, David H. Schnabel - Sales by U.S. Companies of Non-U.S. Businesses [01:14:35]
Michael L. Schler, Brady Plastaras, Erin Cleary, David H. Schnabel - Cross-Border Spin Offs [01:09:08]
Joseph M. Pari, Jodi J. Schwartz, Austin Diamond-Jones, Karen Gilbreath Sowell - UP-Cs and Global Partnership Transactions [01:11:21]
Pamela L. Endreny, William A. Curran, Phillip Gall - Special Luncheon Presentation: The Wrath of Moore [00:43:08]
David M. Schizer, David S. Miller, Julie A. Divola - Inflation Reduction Act (“IRA”) Impact on Acquisitions [01:09:18]
Davis J. Wang, Marie C. Milnes-Vasquez, Jason R. Factor, Marc A. Countryman - Global M&A – Survey of Market Activity and Trends [01:08:58]
Darren G. Heil, David Dubner, William Dixon, Karen Gilbreath Sowell, David H. Schnabel, Jeffrey R. Mensch - Integration of International Businesses Post-Acquisition [01:11:10]
Gary Scanlon, Moshe Spinowitz, Teisha M. Ruggiero, Colleen V. O'Neill, Gordon E. Warnke
The purchase price of this Web Program includes the following articles from the Course Handbook available online:
- Complete Course Handbook
- Sales by U.S. Companies of Non-U.S. Businesses Background Materials
Erin Cleary,Michael Schler,David Schnabel - New York State Bar Association Report on Procedural Guidance for Private Letter Rulings on Divisive Reorganizations: Revenue Procedure 2018-53 and Plan of Reorganization Issues, Report No. 1436 (March 13, 2020)
Karen Sowell - American Bar Association Section of Taxation, Comments on Notice 2015-54 on Transfers of Property to Partnerships with Related Foreign Partners and Controlled Transactions Involving Partnerships (Partnership Tax Issues) (January 7, 2016)
David H Schnabel,Karen G Sowell - New York State Bar Association Report on Section 864(c)(8) Proposed Regulations, Report No. 1414 (March 22, 2019)
David H Schnabel,Karen G Sowell - Brief for the American Tax Policy Institute As Amicus Curiae In Support of Respondent, Charles G. Moore and Kathleen F. Moore v. United States of America, On Writ of Certiorari to the United States Court of Appeals for the Ninth Circuit, No. 22-800 (2023)
Julie Divola, David Schizer, David Miller - New York State Bar Association Report on the Section 4501 Excise Tax on Repurchases of Corporate Stock, Report No. 1469 (November 1, 2022)
Marc Countryman, Karen Sowell - EY Alert, Conditions Ripe for Already Resilient M&A Activity to Accelerate in 2021 and Beyond (December 14, 2020)
Konstantinos Makrygiannis, Karen Sowell - KPMG Report: Initial Observations on Round 4 of CAMT Guidance in Notice 2023-64 (September 25, 2023)
Gordon Warnke - Notice 2023-7: Comments on the Treatment of CFC Dividends and Partnership Taxes (March 20, 2023)
Gordon Warnke
Presentation Material
- Sales by U.S. Companies of Non-U.S. Businesses
David H. Schnabel, Erin Cleary, Brady Plastaras, Michael L. Schler - Cross-Border Spin-offs
Karen Gilbreath Sowell, Austin Diamond-Jones, Joseph M. Pari, Jodi J. Schwartz - UP-Cs and Global Partnership Transactions
Phillip Gall, William A. Curran, Pamela L. Endreny - The Wrath of Moore
David S. Miller, Julie A. Divola, David M. Schizer - Inflation Reduction Act: Impact on Acquisitions
Marc A. Countryman, Jason R. Factor, Marie C. Milnes-Vasquez, Davis J. Wang - Global M&A – Survey of Market Activity and Trends
David H. Schnabel, Karen Gilbreath Sowell, William Dixon, David Dubner, Darren G. Heil, Jeffrey R. Mensch - Integration of International Businesses Post-Acquisition
Gordon E. Warnke, Colleen V. O'Neill, Teisha M. Ruggiero, Gary Scanlon, Moshe Spinowitz
Why You Should Attend
The changes made by the 2017 Tax Act, CARES Act, and the Inflation Reduction Act (“IRA”), and the challenging debt and equity markets have resulted in an uncertain global M&A landscape. At this year’s program, our faculty of recognized tax experts, including representatives from the Internal Revenue Service, will explore cross-border transaction structures and review tax planning considerations in today’s constantly evolving world.
What You Will Learn
After completing this program, participants will be able to:
- Identify opportunities and pitfalls when selling a non-U.S. business
- Determine when a spin-off is the best way to divest a business
- Describe the impact of the Inflation Reduction Act (“IRA”) on cross-border acquisitions
- Recognize planning opportunities in the post-acquisition integration of target and acquirer operations
Who Should Attend
This program is designed for private practitioners, in-house tax professionals and anyone seeking a deeper understanding of the tax planning considerations in structuring international M&A deals in today’s challenging market.
Special Feature: Luncheon presentation “The Wrath of Moore” exploring the potential consequences of the Supreme Court’s decision in Moore vs. United States
Program Level: Overview
Intended Audience: Law firm and accounting firm professionals, in-house tax professionals and government attorneys who want to study the tax planning considerations in structuring international M&A deals.
Prerequisites: An interest in exploring the nuances of tax planning in cross-border M&A.
Advanced Preparation: None