International Tax Transactions II
Availability
On-Demand
Cost
Member: $79.00
Non-Member: $95.00
Retired: $79.00
Educator & Government & Non-Profit Member: $79.00
Credit Offered
2.5 CPE Credits
Field of Study:
  • 2.5 Taxes

When are cross-border transfers non-recognition transactions?

The international tax implications of corporate transfers are wide-ranging. In this course, you’ll learn about the potential tax consequences of inbound Section 351 transfers — for both shareholders and corporations.

You’ll also discover the qualifications for non-recognition under Section 332 for outbound liquidation. Plus, you’ll better understand the interaction between inbound/outbound transactions and Section 367.

Further, the purpose and need for gain recognition agreements are discussed.

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

  • Recognize whether an outbound liquidation qualifies for non-recognition treatment under IRC Section 332.
  • Identify when IRC Section 367 alters the application of the general non-recognition tax rules of IRC Sections 351 and 332.

Key Topics

  • Inbound Section 351 transactions
  • Outbound Section 332 transactions
  • Non-recognition transactions
  • Section 367
  • Gain recognition agreements

Who Will Benefit

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

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