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
After attending this event, participants will be able to
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.
There are no prerequisites for attending this program.
If you are unable to attend this event, you may: transfer your registration to another person from your company for the same event; or transfer your registration to a substitute event listed on our web site. In either instance, there will be no charge or penalty for substitution.To request a transfer, contact customercare@bna.com with the new attendee or substitute event information more than 5 business days prior to the conference start date. On the first day of the event, absent attendees will be considered “no shows” and will not be eligible for a refund, transfer, or substitute event. Cancellations must be made in writing to customercare@bna.com more than 5 business days before the event and will be assessed a $350 conference setup fee. Cancellations will not be accepted if notice is received fewer than 5 business days before the event.For more information regarding administrative policies, such as complaints and cancellations, please contact us at 800.372.1033, or e-mail customercare@bna.com.
Morgan Lewis Conference Center One Market Spear Street Tower, 28th fl. San Francisco, CA 94105Tel: 415-442-1000Hotel accommodations are at your own discretion.We suggest the following:Hyatt Embarcadero – Tel: 415.788.12345 Embarcadero Center, San Francisco, CA
Sheraton Palace – Tel: 415.512.11112 New Montgomery St, San Francisco, CA
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
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.
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 .
Bloomberg BNA offers a hardship policy for CPAs and other tax and accounting professionals who wish to attend our live conference and seminars. Individuals must earn less than $50,000 annually in order to qualify. For individuals who are unemployed or earning less than $35,000 per year, a full discount off the price of registration for the program will be awarded. Individuals earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program.If an individual wishes to submit a case for hardship, he or she must contact Bloomberg BNA directly at accreditations@bna.com. Please include the following information with your request: complete contact information, program for which a hardship reduction is being requested, requested amount for hardship reduction, and reason for applying for hardship. Please note that requests will not be considered until 30 days from the program date and that individuals may only apply for a hardship reduction once within a 12-month period. Bloomberg BNA reserves the right to make a final determination on a case-by-case basis. Our decision for granting a hardship is final and submission does not constitute acceptance.