Tax Issues in International Mergers and Acquisitions
This course focuses on the U.S. tax rules governing cross-border reorganizations, taxable acquisitions and dispositions, and foreign joint ventures. In particular, we will examine the U.S. tax consequences of the outbound transfer of assets, foreign-to-foreign transfers of assets, and inbound transfers of assets. We will specifically address issues arising with the transfer of intellectual property, the financing of foreign acquisitions, the structuring of foreign operations of U.S. multinationals, foreign exchange concerns, and the efficient repatriation of foreign earnings.
Some knowledge of general corporate and international tax principles is helpful, although background materials will be supplied.
The readings will consist primarily of sections of the IRC, regulations, administrative guidance, and some articles addressing tax policy issues raised by the current U.S. international tax regime. For each topic, we will reinforce our knowledge of the relevant provisions by working through problems based on real-world examples.
There will be an in-class final examination.
Prerequisites: Federal Income Taxation or permission of the professor.
Recommended: International Taxation and/or Corporate Taxation (neither is required)