BarbriSFCourseDetails
  1. keyboard_arrow_leftBack

Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Tuesday, June 3, 2025

  • 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.

$347.00

This course is $0 with these passes:

CLE
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. 





-

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio

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 our panel 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

  1. Key provisions impacting inbound and outbound transactions under current U.S. tax law
  2. Utilizing partnerships in deal structures to maximize tax benefits
  3. U.S. versus foreign partnerships: understanding the implications and liability of inbound and outbound transactions
  4. Special allocations: rules and techniques for sellers and purchasers
  5. 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