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International Tax Transactions II

International Tax Transactions II

Earn CPE Credits!

  • Format: Online
  • CPE Credits: 2.5
  • Level: Basic
  • Field of Study: Taxation
Talk to an Expert7,885

International Tax Transactions II

Earn CPE Credits!

  • Format: Online
  • CPE Credits: 2.5
  • Level: Basic
  • Field of Study: Taxation
Talk to an Expert7,885

International Tax Transactions II

This program focuses on the tax treatment of cross-border corporate transfers, particularly where non-recognition rules apply. It examines how international tax provisions influence transactions that would otherwise qualify for tax deferral. Learners explore key areas such as inbound Section 351 transfers, outbound liquidations under Section 332, and the role of Section 367, gaining clarity on when tax consequences arise in global restructuring scenarios.

  • Understand non-recognition rules in cross-border transactions

  • Analyze inbound Section 351 transfers and their tax impact

  • Learn outbound liquidation treatment under Section 332

  • Examine how Section 367 modifies non-recognition provisions

  • Develop awareness of gain recognition agreements and compliance

Who Will Benefit?

Global accounting and finance professionals
Build foundational knowledge of international tax rules governing corporate transfers.
Public and corporate tax professionals
Gain insight into non-recognition provisions and cross-border transaction structures.
Corporate finance and tax teams
Understand tax implications of inbound and outbound restructuring activities.
Professionals working with international taxation
Develop practical understanding of global transfer rules and compliance considerations.

Key areas Covered

Program focuses on core international taxation concepts related to cross-border transfers and non-recognition rules. Participants explore inbound and outbound transactions, Section 367 implications, and gain recognition requirements.

Inbound Section 351 transactions

Understand how property transfers to corporations are treated for tax purposes.

Outbound Section 332 liquidations

Learn when liquidations qualify for non-recognition treatment.

Non-recognition provisions

Explore scenarios where tax deferral applies in international transactions.

Section 367 rules

Examine how international provisions override standard non-recognition rules.

Gain recognition agreements

Understand their purpose and role in cross-border tax compliance.

Course Overview

01
Understand non-recognition frameworks
Learn when cross-border transactions qualify for tax deferral.
02
Analyze inbound and outbound transfers
Examine how Section 351 and Section 332 apply in global contexts.
03
Evaluate Section 367 impact
Understand how international rules modify standard tax treatment.
04
Strengthen compliance awareness
Identify reporting requirements and gain recognition obligations.

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About Authors

This course is developed by experienced subject matter experts, including Ian C. Pereira and Robert Spence, combining practical insights with current international tax regulations.

FAQs

What Skills Will I Gain?

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You will gain foundational knowledge of non-recognition rules, inbound and outbound transactions, and international tax provisions.

How Is the Program Delivered?

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The program is delivered online in a self-paced format with practical examples and real-world scenarios.

Who Should Enroll?

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This course is ideal for tax professionals, finance teams, and individuals working with international corporate transactions.

What Topics Are Covered?

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

How Many CPE Credits Are Offered?

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The program offers 2.5 CPE credits upon successful completion.

What Is the Program Level and Field of Study?

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The program is designed at a Basic level and falls under the Taxation field of study.

Learning Outcomes

Recognize when outbound liquidations qualify for non-recognition under Section 332

Identify how Section 367 modifies non-recognition rules in cross-border transactions

Understand tax implications of inbound Section 351 transfers

Analyze the interaction between inbound and outbound transaction rules

Develop awareness of gain recognition agreements and compliance requirements

Industry-relevant concepts that strengthen expertise in non-recognition transactions and cross-border tax structures.