International Tax Transactions II
Exploring non-recognition transaction rules and the impact of Section 367 on inbound and outbound transactions.
Format
Online
NASBA Field of Study
Taxes
Level
Basic
CPE Credits
2.5
Author(s)
Ian C. Pereira, Robert Spence
Availability
1 year
Product Number
ITCL25SSO
When are cross-border transfers non-recognition transactions?
The international tax implications of corporate transfers are wide-ranging. In this course, you’ll learn about the potential tax consequences of inbound Section 351 transfers — for both shareholders and corporations.
You’ll also discover the qualifications for non-recognition under Section 332 for outbound liquidation. Plus, you’ll better understand the interaction between inbound/outbound transactions and Section 367.
Further, the purpose and need for gain recognition agreements are discussed.
Part of a comprehensive international tax education
This self-study online course is part of the U.S. International Tax Certificate, a comprehensive learning program geared to help global finance and accounting professionals navigate the highly complex world of international taxation.
This course can be purchased individually or as part of the U.S. International Tax: Advanced Issues bundle. You must purchase the bundle to earn the digital badge.
Who Will Benefit
Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.
Key Topics
- Inbound Section 351 transactions
- Outbound Section 332 transactions
- Non-recognition transactions
- Section 367
- Gain recognition agreements
Learning Outcomes
- Recognize whether an outbound liquidation qualifies for non-recognition treatment under IRC Section 332.
- Identify when IRC Section 367 alters the application of the general non-recognition tax rules of IRC Sections 351 and 332.
Group ordering for your team
2 to 5 registrants
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US customers call 1-800-634-6780 (option 1)
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