International Update - Tax Executives Institute PowerPoint Presentation


In this Presentation:

- Topics

- Inversion

- Inversions – How Did We Get Here?

- Impact Of The §367 Regulations

- 2003 – Enactment of §7874

- §7874

- Determining “Ownership”

- Treasury Regulation 1.7874-4T – Disqualified Obligations

- Treasury Regulation 1.7874-4T – De Minimis Exception

- Subsequent Transfers 1.7874-5T

- Internal Restructuring

- Subsequent Transfers of Stock & the EAG Rules

- Subsequent Transfers & the EAG Rules

- Subsequent Transfers and the De Minimis Exception: “Inversions over Time?”

- Substantial Business Activities

- Post 2012 Migration - ENSCO

- Inversion by Combination

- Does §367 Always Hit?

- §367

- Post Inversion Planning


- Example

- Actions Needed

- About the OECD

- 15 Actions

- U.S. Approach to BEPS Project

- Hybrid Mismatches – Action 2

- Treaty Abuse – Action 6

- Digital PE – Action 1

- Transfer Pricing Documentation – Action 13

- Cross Border Tax Disputes – Notice 2013-78

- Notice 2013-78

- Transfer Pricing and Secondary Effects

- Excerpt from Topics:

- Inversions - §7874 and merger mania

- BEPS – what is it and how will it affect you?

- Changes to accessing competent authority – welcome expansion, and impact on your IRS audit procedures...

Please see full Presentation below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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