Self-Study

International Tax Transactions I

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The tax treatment of corporate reorganizations and liquidations is complicated enough when dealing only with domestic entities. When reorganizations and liquidations span different countries, there's an additional layer of complexity.

This course explores Section 367(b) transactions through an international tax lens, helping tax professionals understand the relationship between corporate exchange and international tax provisions.

This course also discusses the tax implications of Section 7874 inversions and foreign stock acquisitions under Sections 338 and 304. Through illustrative examples, you'll better understand the mechanics of these transactions.

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.

Major subjects

• Reorganizations and liquidations under Section 367(b).
• Stock acquisitions (including Section 338).
• Inversion rules under Section 7874.
• Related party stock sales.

Learning objectives

• Identify whether a reorganization or restructuring may qualify as an "inversion" subject to the rules of Section 7874.
• Recognize the implications of making a Section 338 election in an acquisition of foreign corporate stock from a third party.

Who should take this program?

• Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.

Pricing

Our records indicate you are a nonmember. If you register, you will be charged $85.00 (Standard Nonmember Fee). Members: Please log in to receive member fee.

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