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US Tax Aspects of International Acquisitions & Reorganizations


May 30 - 31, 2013
Chicago, IL
Product Code: TMC88
$1395.00 Regular Price
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Join us for a two-day intermediate to advanced level course with live group instruction on strategies for international acquisitions and reorganizations.

Course Level: intermediate to advanced; Delivery Method: live group

Learning Objectives

After attending this event, participants will be able to

  • Provide an Overview of Subchapter C Acquisition and Reorganization Rules
  • Discuss Section 367(a): Asset Transfers
  • Describe Corporate Reorganizations: Final Section 367(b) Regulations
  • Explain Section 367(a): Stock Transfers
  • Explain Section 367(d): Transfer of Intangibles
  • List Current Developments in International M&A
  • Describe Sections 355 and 367(e)(1)
  • Outline Internal Restructuring: Section 304 Issues
  • Discuss Taxable Acquisitions and Dispositions of Foreign Corporations
  • Describe Taxable Aspects of International Acquisitions & Reorganization 367[b]
  • Describe Regulations on Earnings & Profits on Foreign Income Tax Carryover

All paid attendees will receive the Bloomberg BNA Portfolio: #919 - 3rd U.S. to Foreign Transfers Under Section (367) a
*One Portfolio per paid attendee. Quantities are limited.

Prerequisites

There are no prerequisites for attending this program.

 

SUBSTITUTIONS, CANCELLATIONS & COMPLAINTS

Cancellations received more than 72 business hours prior to the meeting will be issued a credit. A $350 fee will apply to cancellations received within 72 business hours of the event. No credit card or cash refunds will be issued at any time. For more information regarding administrative policies, such as complaints and refunds, please contact us at 800.372.1033, or e-mail customercare@bna.com. Credits will not be issued for "no shows".

Chicago - McDermott Will & Emery Conference Center
227 W. Monroe St #4700
Chicago, IL 60606
Tel: 312.372.2000

Day One

7:30 a.m. Registration and Continental Breakfast  
 

8:20 a.m. Introduction by Chairperson  
 

8:30 a.m. Overview of Subchapter C Acquisition and Reorganization Rules
 
9:45 a.m. Refreshment Break
 
 

10:00 a.m. Section 367(a): Asset Transfers
 
11:00 a.m. Corporate Reorganizations: Final Section 367(b) Regulations
 
12:00 p.m. Luncheon
 
 

1:00 p.m. Section 367(a): Stock Transfers
 
2:15 p.m. Section 367(d): Transfer of Intangibles
 
3:45 p.m. Current Developments in International M&A
 
5:00 p.m. Questions & Answers
 
 

5:15 p.m. Meeting Adjourns
 

Day Two

7:30 a.m. Continental Breakfast
 

8:30 a.m. Sections 355 and 367(e)(1)

9:15 am Refreshment Break 

 

9:30 a.m. Internal Restructuring: Section 304 Issues
 
12:15 p.m. Luncheon 

 

10:45 a.m. Taxable Acquisitions and Dispositions of Foreign Corporations
 
12:00 p.m. Luncheon
 
 

1:00 pm Taxable Aspects of International Acquisitions & Reorganization 367[b]
Regulations on Earnings & Profits on Foreign Income Tax Carryover
 
 

2:15 p.m. Questions & Answers  
 

2:30 p.m. Seminar Concludes

EDUCATIONAL COURSE CREDIT


Up To 14.5 CPE Credit hours available

Bloomberg BNA is registered with the National Association of the State Boards of Accountancy 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. Complaints regarding registered sponsors may be addressed to NASBA, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417.

Up to 14.5 CLE Credit hours available

Bloomberg BNA will apply for continuing legal education credits in any state or jurisdiction where available. For more information, please contact Bloomberg BNA customer service at 800.372.1033 and ask to speak to the CLE Accreditations Coordinator, or email us at accreditations@bna.com .

Hardship Policy

Bloomberg BNA offers a hardship policy for attorneys earning less than $50,000 per year. If an attorney wishes to take advantage of this option, he or she must contact Bloomberg BNA directly. For attorneys who are unemployed or earning less than $35,000 per year, a full discount off the price of the program will be awarded upon written proof of hardship. Attorneys earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program. Any attorney working in the public service sector also qualifies for a special price. If you have further questions regarding the hardship policy or seek additional information, please contact Bloomberg BNA customer service at 800.372.1033 and ask to speak to the CLE Accreditations Coordinator, or email us at accreditations@bna.com.