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Transfers of Tangible and Intangible Property to a Foreign Corporation

Gain a better understanding of the reporting requirements of transfers to foreign corporations.U.S. corporations can transfer appreciated property in a wide variety of nonrecognition transactions such as reorganizations, capital contributions, and corporate liquidations. However, when such normal nonrecognition transactions result in transfer of property to a Foreign Corporation (FC), U.S. tax law imposes restrictions on the tax-free transfer of certain types of property by override of the normal nonrecognition rules. There is an override of the nonrecognition provisions because the gain on the appreciated property would permanently escape U.S. tax upon the outbound transfer of the property to the FC. Further, these rules give the IRS the authority to preserve their ability to impose U.S. income tax currently, or at a later time, on the accumulated E&P of certain foreign corporations. The purpose of this course will be to give participants an overview of the US outbound transfer of property to foreign corporations, discuss the mechanics, special transfer rules and creative strategies for dealing with US based appreciated property.
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Why Lorman?

Over 30 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Overview of the U.S. Outbound Transfer Rules
  • Purpose of the Rules
  • When Outbound Transfers Receive Nonrecognition Treatment
  • When Outbound Transfers Are Taxable
Mechanics of U.S. Outbound Transfers
  • Terms and Acronyms
  • Timely Compliance
  • Exceptions to Filing
Special Transfer Rules
  • Partnership
  • Spouses
  • Cash
  • Stock or Securities for Which a Gain Recognition Agreement (GRA) Is Filed
  • Distributions by Domestic Liquidating Corporations
Creative Strategies
  • Worthless Stock Loss
  • Pre-Acquisition Planning
  • Transfer Pricing
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Why Lorman?

Over 30 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

Audio & Reference Manual

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • GA CLE 1.7
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.75
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program format does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.75
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program format does NOT qualify, nor meet the National Standard for NASBA accreditation.

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More Program Information

Why Lorman?

Over 30 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Ryan Gaglio

Ryan Gaglio

Baker & Hostetler LLP

  • Partner with Baker & Hostetler LLP
  • Focuses on tax planning, tax controversy and transactional matters
  • Advises clients on the federal, state and local tax consequences of mergers and acquisitions, bankruptcies and workouts, executive compensation, as well as tax planning for inbound and outbound transactions, intercompany transfer pricing, foreign currency transactions, and other international tax matters
  • Published several articles and is the co-editor of a comprehensive tax treatise, Taxation of Securities Transactions “Overlooked Impact of Health Care Reform,” Daily Journal (August 31, 2012)
  • J.D. degree, Yale Law School; B.A. degree, Columbia College
  • Can be contacted at 714-966-8806 or [email protected]
John P. Garcia, CPA, M.B.A.

John P. Garcia, CPA, M.B.A.

Corporate Tax Advisors

  • Owner of Corporate Tax Advisors, a California based professional services company specializing in providing accounting, tax, and training services for mid-sized corporations with an international footprint
  • More than 25 years of experience providing services to major multi-national corporations such as Billabong, Nixon, Targus, Marriott, Dial, Henkel, The University of Phoenix, and CPE, Inc
  • His firm conducts regular seminars and workshops on the following: Accounting for Income Taxes – ASC 740/FAS 109; International Taxation; State and Local Taxation; Uncertain Tax Positions – FIN 48 and Transfer Pricing
  • Wrote the SRR Journal – Fall 2016 – How to Properly Capitalize Subsidiaries Without Getting Ensnared in the Earnings-Stripping Rules; California CPA magazine – June 2013 – An Integrated Database Solution to Global Withholding Compliance and Thomson Reuters - Corporate Taxation – December 2009 – Green Corporate Tax Incentives-Wind Technologies
  • B.S. degree in accounting and finance, University of Maryland College Park; M.B.A. degree in international business, University of Phoenix
  • Member of California Society of CPAs and AICPA
  • Can be contacted at 877-728-1400, [email protected] or www.ctaxadvice.com
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Why Lorman?

Over 30 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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Product ID: 399674
Published 2017
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