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

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. 

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.

  
  

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IRS Approved Provider

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