The discussion will focus on the impact of both recent and pending tax law changes in the United States and other countries, and of IRS regulatory developments, on cross-border transaction planning. After completing this session participants will be able to:

Better understand the impact of the new Corporate Alternative Minimum Tax on M&A transactions
Identify issues for M&A transactions that arise as foreign countries implement OECD Pillar 2 over the next two years
Understand developing issues in cross-border M&A transactions, including the current views of the IRS regarding changes to the Section 367 regulations to reflect the enactment of Section 245A and GILTI in TCJA

Tijana J. Dvornic, John J. Merrick, Eric B. Sensenbrenner, Wade Sutton

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