transcript   Transcript

Impact of 2017 Tax Act on Cross-Border Acquisitions and Divestitures

Recorded on: Oct. 22, 2018
Running Time: 01:17:02

Full Transcript:



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Taken from the Web Program Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2018 Recorded October 2018 in New York

Impact of 2017 Tax Act on Cross-Border Acquisitions and Divestitures [01:17:02]

Key corporate and shareholder tax issues; impact of lower corporate rates and limitations on losses and deductions; impact of global intangible low-taxed income (“GILTI”) on purchase transactions; changes to the foreign tax credit rules; some surprising changes affecting cross-chain transfers among affiliated corporations; impact of new rules on some of the negotiating dynamics between buyers and sellers over issues such as a pre-closing tax indemnity and control of post-closing examinations.

Kimberly S. Blanchard, Nicholas J. DeNovio, Hal Hicks, Shane M. McCarrick [Senior Counsel, Office of the Associate Chief Counsel (International, Branch 4), Internal Revenue Service]

The purchase price of this Web Program segment includes the following article from the Course Handbook available online:
  • Latham & Watkins White Paper—US Tax Reform: Key Business Impacts, Illustrated with Charts and Transactional Diagrams, No. 2266 (January 10, 2018)
    Nicholas J. DeNovio
  • Latham & Watkins Client Alert Commentary—Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform, No. 2355 (July 26, 2018)
    Nicholas J. DeNovio
Presentation Material
  • Impact of 2017 Tax Act on Cross-Border Acquisitions
    Kimberly S. Blanchard, Nicholas J. DeNovio, Hal Hicks
  • (s)
    Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
    Nicholas J. DeNovio ~ Latham & Watkins LLP
    Hal Hicks ~ Skadden, Arps, Slate, Meagher & Flom LLP
    Shane M. McCarrick ~ Senior Counsel, Office of the Associate Chief Counsel (International, Branch 4), Internal Revenue Service
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