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  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparer
  • schedule 110 minutes

Corporate Tax Developments: Tariffs and M&A, Relation Back Doctrine, Recent PLRs

$197.00

This course is $0 with these passes:

CPE
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Description

Recent political and tax changes have significantly impacted domestic and international businesses. Tariffs imposed by the Trump administration on Canada, China, Mexico, and other countries create additional due diligence considerations for M&A transactions. Uncertainties and additional risks need to be incorporated in these combinations.

In September 2024, the IRS released CCA 202436010, stating that controlled foreign corporations (CFCs) are not entitled to the dividends received deduction under Section 245A. Corresponding regulations are anticipated.

Whether from FTC adjustments made by other countries or a decision to take a foreign tax credit rather than a deduction, foreign tax amounts are frequently redetermined. Issued in 2022, Treas. Reg. §1.905-1(d)(1)(ii) states that the FTC cannot be claimed until any disputes are resolved and a final amount determined. The IRS' interpretation of the relation back doctrine relative to this regulation can result in FTC tax changes being time-barred, subjecting taxpayers to double taxation. 

In addition to the items above, numerous PLRs and cases impact MNEs, their advisers, and corporate taxpayers in general. 

Listen as our panel of federal tax experts reviews recent corporate tax developments and the impact of these on domestic and international businesses. 

Presented By

Surbhi Bordia
Partner
Armanino, LLP

Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact international companies’ operations and puts tax efficient structures in place for her clients. Ms. Bordia’s hands-on experience in international tax, IP migration planning and legal entity rationalizations make her an expert consultant and key team player for clients in mergers and acquisitions. Ms. Bordia’s focus areas include GILTI, BEAT, FDII, anti-hybrid rules, foreign tax credits, subpart F, withholding tax, investments in U.S. property, FX gains and losses, treaty-related issues, outbound transfers and permanent establishment and profit attribution rules.

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Vikram Sharma
Attorney, Senior Manager, National Tax Office
Armanino, LLP

Mr. Sharma is a Senior Manager at the National Tax Office of M&A at Armanino. He consults private equity, growth equity and strategic corporate clients in navigating complex tax implications of mergers and acquisitions transactions. Mr. Sharma's experience encompasses advising on tax structures for various M&A transactions including leveraged buyouts, secondary buyouts, institutional buyouts, spin-offs, corporate reorganizations, conversions, and the utilization of net operating losses. He also provides strategic guidance on the tax aspects of forming of private equity funds, joint ventures, SPACs, refinancings, distressed sale of assets and bankruptcy reorganizations. Mr. Sharma is also an attorney admitted in New York and India.

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Pierre Yapo
Senior Manager, National Tax Office
Armanino, LLP

Mr. Yapo a Senior Manager in the National Tax Office (Mergers and Acquisitions) of Armanino Advisory LLC. He advises both private equity investors and strategic corporate buyers and sellers on all matters of income and non-income tax structuring, tax due diligence, and tax modelling of domestic and cross-border inbound (foreign to US) and outbound (US to foreign) transactions. Mr. Yapo completed his graduate studies (Master of Science in Accountancy - tax concentration) at the University of Notre Dame, and his undergraduate studies (Bachelor of Science - accounting), with honors (cum laude), at Illinois State University.

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Credit Information

  • 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).

Date + Time

  • event

    Thursday, June 5, 2025

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. Corporate tax developments: introduction

II. Tariffs and M&A

III. Relation back doctrine

IV. Original of claim doctrine

V. Recent corporate private letter rulings

VI. IRS Memo on Section 245A(a) to dividends

VII. Other developments

The panel will review these and other critical issues:

  • The impact of current tariffs on mergers and acquisitions
  • IRS stance on the dividend received deduction for CFCs
  • Recent PLRs that affect businesses
  • Steps practitioners and companies need to take considering recent corporate tax developments

Learning Objectives

After completing this course, you will be able to:

  • Identify actions to take in light of recent corporate tax developments
  • Determine how recent tariffs impact M&A
  • Ascertain the impact of CCA 202436010 on CFCs
  • Decide how IRC Section 704(c) affects waterfall allocations
  • 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 preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.


BARBRI 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.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .