About the Course
Introduction
This CLE course will highlight emerging tax developments U.S. buyers and sellers must consider when structuring cross-border M&A transactions, along with practical planning guidance for M&A attorneys. From upfront tax assessments through post-transaction integration, the course will address key tax and corporate considerations for planning cross-border deals.
Description
Merging with or acquiring a company is complex even in basic circumstances, but cross-border M&A adds additional planning hurdles, legal obligations, and more significant tax-planning challenges. Businesses must assess the target company's local tax regime, double tax treaties, and related issues to determine whether a deal offers tax advantages or creates greater liabilities—an analysis that often affects financing. As multinational deals face heightened scrutiny from tax authorities worldwide, understanding the interplay between U.S. and foreign tax regimes is essential to preserving deal value and avoiding costly missteps.
This webcast will help M&A professionals structure more efficient transactions with an emphasis on tax consequences. This program will help practitioners navigate anti-deferral regimes, avoid compliance missteps, and advise buyer and seller clients with a better appreciation of a deal's tax obligations. The faculty will address key tax assessments for cross-border due diligence, examining deal structure options and how structures affect tax burdens and financing, and other practical planning considerations. They will also spotlight the One Big Beautiful Bill Act's (OBBBA) effect on CFC income in cross-border M&A, other tax developments, and emerging international tax changes.
Listen as our authoritative panel discusses cross-border M&A and the tax issues and deal structuring strategies that will help buyers and sellers maximize outcomes.
Presented By
Mr. DeFeo focuses his practice on domestic and international capital markets, corporate finance and M&A transactions, and corporate governance and compliance counseling for boards, committees and directors of public and private companies and not-for-profit entities. He advises public and private corporations, partnerships, limited liability companies, real estate investment trusts, and other clients in U.S. and cross-border joint ventures and strategic alliances, M&As, consolidations, asset and stock acquisitions and dispositions; and public and private offerings of debt and equity securities, including initial public offerings and shelf-registered offerings, Rule 144A high-yield debt offerings and exchange listings.
Mr. Patrick assists clients on a wide range of United States tax matters associated with domestic and international business transactions and generally navigating the increasingly complex global tax environment. His practice focuses on mergers and acquisitions and other transactional tax matters, including debt and equity offerings, corporate and partnership restructurings, and joint ventures. Mr. Patrick has also represented clients with regard to multijurisdictional disclosure and reporting regimes (U.S. Corporate Transparency Act, FATCA, the CRS, and DAC6/MDR). Additionally. He has experience advising high-net-worth individuals, their private businesses and family offices, and other fiduciaries on cross-border tax, private banking, trust, and estate planning matters, including pre-immigration and expatriation planning and U.S. federal and state tax regularization.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Wednesday, September 23, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Cross-border deal basics
A. Latest trends and developments in cross-border M&As
B. Examining potential legal, business, financial, political, and regulatory issues
C. Deal strategies and planning essentials
D. Federal and state taxes; key tax drivers of inbound and outbound transactions; tax treaties and international regime considerations
II. Examining deal structures
A. Benefits and drawbacks of certain types of structures and their tax impact
B. Inbound domestications and anti-inversion rules: tax consequences and planning for them
III. Best practices for conducting due diligence and implementing risk mitigation measures
IV. Withholding, transfer pricing, and repatriation
V. Term sheet must-haves; post-transaction implementation and obligations; tax surprises
VI. OBBBA and other emerging developments: key changes and taxation impacts
VII. Pillar Two and the side-by-side safe harbor on TopCo jurisdiction decisions
The panel will review these and other critical issues:
- How should a cross-border M&A transaction be managed to best achieve the desired outcome?
- What are key considerations when conducting due diligence in cross-border M&A deals?
- How should M&A counsel evaluate the tax burdens associated with available structures?
- What structuring strategies will help mitigate global tax exposure?
- How to negotiate and draft term sheets that mitigate risk and leverage tax planning benefits
Related Courses
Cross-Border M&A Planning Strategies and Tax Developments: Structuring, Compliance, and Risk Mitigation
Wednesday, September 23, 2026
1:00 PM ET/10:00 AM PT
