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Please join us for our webcast Cross-border mergers &
acquisitions update for a discussion on recent guidance issued by
the IRS and Treasury Department in the cross-border mergers and
acquisitions (M&A) area.Joe Calianno, Grant Thornton's
International Technical Tax practice leader, will be joined by
Brenda Zent, international tax specialist in the U.S. Department of
the Treasury's Office of International Tax Counsel, as
presenters for this event.
Topics will include:
Notice 2012-39 dealing with the application of Section 367 (d)
to transfers of intellectual property in outbound asset
reorganizations,
Notice 2012-15 dealing with the application of Section 367 to
related-party stock sales under Section 304,
recent regulations issued under Section 7874 dealing with
inversion transactions,
the application of Section 901(m) to Section 338 transaction
and other selected transactions, and
other international tax guidance in the cross-border M&A
area.
Learning objectives:
Learn about recent guidance issued by the IRS and Treasury
Department in areas related to cross-border M&A.
Understand how this recent guidance may impact transactions
that your company may be undertaking.
Featured presenters:
Joe Calianno, partner and international technical tax practice
leader, Grant Thornton LLP
Brenda Zent, international tax specialist, U.S. Department of
the Treasury's Office of International Tax Counsel
Locate the webcast, ID: 59769, Cross-border mergers
& acquisitions update webcast, in the catalog and
press the 'Enroll' button.
Look for an email from LearnLive Technologies confirming
your registration.
If you have any questions or encounter any technical
difficulties while enrolling, please contact LearnLive technical
support at 888.228.0988 or email GT_support@learnlive.com.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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The Internal Revenue Service has recently published an IRS Large Business & International Directive, which updates an earlier directive to field agents addressing the examination of capitalization and repair costs issues.
A state cannot include income in the apportionable base and then exclude the receipts and related factors that generated that very same income from the apportionment formula.