On-Demand   MP3 Audio
  Also Available in:  On-Demand On-Demand One-Hour Briefing

IRS and Treasury’s New Guidance Issued Under Sections 7874 and 385

Recorded on: May. 2, 2016
Running Time: 01:00:50

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam.


Lecture Topics  [01:00:50]

Upon the successful completion of this program, the participant will be able to:

  • Understand inversion transactions and the potential impact on certain-publicly traded companies stemming from federal regulation of inversions.
  • Recall the New Provisions under section 7874 impacting inversion transactions.
  • Recognize the potential impact of the Proposed Regulations under section 385.

Course Overview: 

This program will focus on:

  • Inversion transactions and the New Provisions in Temporary Regulations under section 7874.
  • Proposed Regulations under section 385 regarding IRS treatment of certain related-party debt instruments.
  • The potential impact of the recent guidance issued under both sections 7874 and 385.

CPE Program Level:

Overview

Intended Audience:

Financial and legal professionals, particularly lawyers and accountants, and other allied professionals, advising clients as to inversion transactions and related-party debt instruments.

Prerequisites:

A background in Internal Revenue Code provisions regulating inversion transactions and the IRS treatment of related-party debt instruments.

Advance Preparation:

None

Instructional Method:

QAS Self-Study

Updated:

August 2016

Speaker(s)
John J Merrick ~ Senior Level Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Joshua D Odintz ~ Baker & McKenzie LLP
Eric B Sensenbrenner ~ Skadden, Arps, Slate, Meagher & Flom LLP
Raymond J Stahl ~ Special Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Brenda L Zent ~ Special Advisor on International Taxation, Office of Tax Policy, U.S. Department of the Treasury
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