The U.S. taxes U.S. corporations on their worldwide income, and has among the highest corporate tax rates in the world. This has led to a number of large U.S. corporations engaging in inversion transactions, in an effort to both avoid the U.S. tax on their foreign operations and to shift income to lower tax rate jurisdictions. The current Administration, Congress and the Treasury have all targeted inversion transactions as being abusive. This slide deck focuses on the main provisions of Section 7874, the post-inversion tax planning that often accompanies an inversion transaction, and the ways in which the Treasury and the Administration plan on challenging such transactions.
Agenda
Faculty
Charles S. Kolstad
Withers Bergman LLP
- Tax partner Withers Bergman LLP, a leading international private capital law firm, specializing in international tax matters
- Focuses his practice on international tax, corporate, and partnership matters; he assists clients in tax and corporate planning relating to the acquisition, disposition and restructuring of businesses, corporations and partnerships both domestically and internationally
- Frequently advises foreign individuals moving to the U.S. on pre-immigration, income, gift and estate tax planning opportunities; he also focuses his practice on the cannabis industry/cannabusiness, crypto assets and block chain technology, and tax issues related to initial coin offerings (ICOs)
- Has advised over 200 clients with unreported foreign 1nancial accounts, foreign trusts, and other foreign investments, on the 1ling of FBARs and other information returns, and whether participating in the IRS’s various offshore voluntary disclosure programs is appropriate
- Written and lectured on the extensive information reporting requirements for U.S. taxpayers with international business operations
- During his career he’s been at Mitchell Silberberg & Knupp LLP and Venable LLP and was a tax partner at both Coopers & Lybrand and Ernst & Young
- J.D. degree, The University of Notre Dame; M.B.A. degree, Columbia University; B.Sc. degree, Villanova University
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