Tax Issues in Inbound and Outbound Transactions | CLE/CPE Course

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Course Details

Course Information

smart_display Format
On-Demand
signal_cellular_alt Difficulty Level
Intermediate
work Practice Area
Tax Law

Date & Time

event Date
Thursday, June 1, 2023
schedule Time
1:00 p.m. ET./10:00 a.m. PT
timer Program Length
90 minutes

Credit Information

This 90-minute webinar is eligible in most states for 1.5 CLE credits.
BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00

CLE

CPE

ALL

This CLE/CPE course will guide tax counsel and professionals on tax challenges and opportunities in utilizing partnerships for inbound and outbound transactions. The panelist 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.

Faculty

Ulises Ruiz

Principal

Prager Metis CPAs

Mr. Ruiz is the Principal-In-Charge for the International Tax Department of Prager Metis, a member of Prager Metis International Group. He has more than 25 years of experience in the accounting industry and has earned his Juris Doctorate and LLM degree.

Mr. Ruiz has over twenty years of experience specifically in international tax niche with a specialization in tax advisory, tax planning, structuring and compliance. He represents high-net-worth clients, manufacturing and distribution companies, public companies, real estate clients, and technology-based companies.

His area of expertise lies in helping companies and individuals with cross-border tax issues alongside providing advisory functions to help optimize tax profile of international business.

Mr. Ruiz is a noted industry expert and has been a prolific speaker and author on topics pertaining to international taxation. He has participated by providing his valuable insights in articles like Bloomberg’s BNA tax management portfolios, foreign income-based transfer pricing on rules and practice in selected countries and more.

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Description

Inbound and outbound transactions between the U.S. and other countries can lead to a host of tax implications requiring careful tax planning to avoid any unintended liability. Tax counsel and advisers must understand the complex rules impacting these transactions applicable to both U.S. and foreign entities.

Tax reform created tax planning obstacles for outbound and inbound transactions. Outbound transactions involve U.S. taxpayers doing business or investing in foreign countries while inbound transactions involve foreign taxpayers doing business or investing in the United States. The type of entity used in a transaction along with the timing of elections and proper filing can all dramatically impact the tax implications of the transaction. Utilizing partnerships can provide tax benefits to both U.S. and foreign taxpayers if properly implemented.

It is essential that tax counsel and advisers recognize the issues and opportunities in using partnerships in structuring inbound and outbound transactions for both tax planning and compliance. Grasping an understanding of applicable tax law, special allocation rules, and key tax aspects of the deal structure will ensure tax benefits for all parties involved in a transaction.

Listen as Ulises Ruiz, JD, LLM, Principal at Prager Metis CPAs, discusses complex U.S. tax laws impacting inbound and outbound transactions, effectively using partnerships in deal structures to maximize tax benefits, and special allocations and key tax aspects to consider for inbound and outbound transactions.

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 panelist 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

NASBA Details

Learning Objectives

After completing this course, you will be able to:

Identify critical provisions of current tax law impacting inbound and outbound transactions
Recognize tax-saving mechanisms in utilizing partnerships in inbound and outbound transactions
Understand tax aspects of acquisition agreements and pitfalls to avoid
Understand special allocation rules and concepts for tax savings for inbound and outbound transactions

Field of Study: Taxes
Level of Knowledge: Intermediate
Advance Preparation: None
Teaching Method: Seminar/Lecture
Delivery Method: Group-Internet (via computer)
Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex income tax forms and schedules for partnerships and pass throughs; supervisory authority over other preparers/accountants. Knowledge and understanding of partnership structures, dissolution and related taxation; Familiarity with sale and redemption of a departing partners interest, and characterizing gain and loss determined upon a transfer.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.