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Leveraging Outbound Transfers of Corporate Stock and Other Property

Webinar: ID# 1015078
Recorded CD
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About This Course:
In November 2014, the U.S. Internal Revenue Service (IRS) issued final regulations revising the reporting rules applicable to stock and property transfers under Internal Revenue Code §§367 and 6038B. The final regulations clarify the rules that apply for transfers of property to foreign corporations (outbound transfers).

U.S. or foreign persons use outbound transfers as a way to minimize or avoid U.S. tax on the profits from the sale. Under the final regs, the full amount of gain on an outbound transfer must be recognized only if a failure to comply with §367 reporting obligations was willful.

However, the final rules are not all a win for taxpayers. The final regs do away with a 2010 directive allowing for corrections in documents related to gain recognition agreement (GRA) filings. Further, §6038B now calls for specifics on FMV, basis and gain recognized when filing a GRA. Counsel and clients must carefully consider how outbound transfers should be utilized.

Listen as our authoritative panel discusses outbound transfers, IRC §367(a) and its gain recognition agreement requirements. The panel will also discuss the IRS final rules and reporting rules under Section 6038B, considerations for avoiding GRAs, and the final regulations.

Outline
  • Transactions that fall under IRC §367
  • IRS final rules (Nov. 2014)
  • Considerations for avoiding GRAs
  • Best practices for leveraging outbound transfers and minimizing taxes
Benefits

The panel will review these and other key issues:
  • When should a company file a GRA as part of an outbound transfer? When should they avoid filing a GRA?
  • How do the final regulations impact outbound transfers and GRAs?
  • What are the reporting requirements for outbound transfers? How did the final regulations change these requirements?
Learning Objectives

After completing this course, you will be understand:
  • What triggers require the filing of GRAs? When should GRAs seek to be avoided?
  • How do the final regulations impact outbound transfers and GRAs?
  • What are the reporting requirements for outbound transfers? How did the final regulations change these requirements?


Credits Available

This program has been approved for 2.0 CPE hours through Strafford Publications. CPE Credit is available only for the LIVE webcast. Recorded versions do not qualify for credit.

Strafford is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit.

Processing

To obtain CPE credit, attendees must participate in the live event, return an Official Record of Attendance to Strafford affirming their participation (including the CPE code announced during the program), and pay a processing fee of $35 per person.

Credit Confirmation

Strafford will mail a certificate of credit within approximately 2 weeks of receiving an attendee's completed Official Record of Attendance—provided all required conditions have been satisfied.



Delivery

Handout materials and the phone number for live presentations are made available to you 1 day prior to the event via email from the presenter. Copies of the presentations are included with recorded versions.

If you order a recorded version of the webinar, CD's will be mailed out approximately 10 days after the live event. Shipping is included in the price of recorded versions.
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Leveraging Outbound Transfers of Corporate Stock and Other Property
Available on CD format
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