OasisLMS

Understanding tax consequences of cross-border reorganizations and liquidations

The tax treatment of corporate reorganizations and liquidations is complicated enough when dealing only with domestic entities. When reorganizations and liquidations span different countries, there’s an additional layer of complexity.

This course explores Section 367(b) transactions through an international tax lens, helping tax professionals understand the relationship between corporate exchange and international tax provisions.

Inversions and foreign stock acquisitions

This course also discusses the tax implications of Section 7874 inversions and foreign stock acquisitions under Sections 338 and 304. Through illustrative examples, you’ll better understand the mechanics of these transactions.

Part of a comprehensive international tax education

This self-study online course is part of the U.S. International Tax Certificate, a comprehensive learning program geared to help global finance and accounting professionals navigate the highly complex world of international taxation.

This course can be purchased individually or as part of the U.S. International Tax: Advanced Issues bundle. You must purchase the bundle to earn the digital badge.

Learning Outcomes

• Identify whether a reorganization or restructuring may qualify as an “inversion” subject to the rules of Section 7874.
• Recognize the implications of making a Section 338 election in an acquisition of foreign corporate stock from a third party.

Key Topics

• Reorganizations and liquidations under Section 367(b)
• Stock acquisitions (including Section 338)
• Inversion rules under Section 7874
• Related party stock sales

Who Will Benefit

Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.