Tax Issues in Inbound and Outbound Transactions: Utilizing Partnerships to Maximize Tax Benefits
Presented by Strafford Publications, Inc.
Inbound and outbound transactions between the U.S. and other countries can lead to a host of tax implications requiring careful tax planning to avoid any unintended liability. Tax counsel and advisers must understand complex rules impacting these transactions applicable to both U.S. and foreign entities.
Tax reform created tax planning obstacles for outbound and inbound transactions. Outbound transactions involve U.S. taxpayers doing business or investing in foreign countries while inbound transactions involve foreign taxpayers doing business or investing in the United States. The type of entity used in a transaction along with the timing of elections and proper filing can all dramatically impact the tax implications of the transaction. Utilizing partnerships can provide tax benefits to both U.S. and foreign taxpayers if properly implemented.
It is essential that tax counsel and advisers recognize the issues and opportunities in using partnerships in structuring inbound and outbound transactions for both tax planning and compliance. Grasping an understanding of applicable tax law, special allocation rules and key tax aspects of the deal structure will ensure tax benefits for all parties involved in a transaction.
Listen as our panel discusses complex U.S. tax laws impacting inbound and outbound transactions, effectively using partnerships in deal structures to maximize tax benefits, and special allocations and key tax aspects to consider for inbound and outbound transactions.
Key topics include:
- Critical provisions of current U.S. tax law impacting inbound and outbound transactions
- Effectively using partnerships in inbound and outbound transactions to ensure tax benefits
- Structuring the deal and understanding the differences and potential traps for foreign and U.S. partnerships
- Understanding special allocation rules and concepts to revise deal structures for tax savings under U.S. tax law
- Key tax aspects of acquisition agreements and drafting tips to avoid tax pitfalls