The Council for International Tax Education (CITE) presents
Tax Aspects of International Acquisitions &
Reorganizations
November 11 & 12 - San Francisco
A two-day technical update on the complex issues under Sec.367 and their interrelationship with the Subchapter C provisions of the Internal Revenue Code
Benefits of Attending
- M&A Washington update
- Overview of Subchapter C including acquisition and reorganization rules
- Corporate reorganizations: final Section 367(b) regulations
- Taxable acquisitions and dispositions of foreign corporations
Educational Course Credit — Up to 14.5 CPE / CLE Credits Available
Substitutions/Cancellations
Cancellations received more than 72 business hours prior to the meeting will be issued a credit. A $350 fee will apply to cancellations received within 72 business hours of the event. No credit card or cash refunds will be issued at any time. For more information regarding administrative policies, such as complaints and refunds, please contact us at 1-914-328-5656, or e-mail info@citeusa.org. Credits will not be issued for "no shows"
Meetings held at conference centers do NOT have rooms blocked
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San Francisco - Morgan Lewis & Bockius Conference Center |
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1 Market Street |
Day One
7:30 a.m. Registration and Continental Breakfast
8:20 a.m. Introduction by Chairperson
8:30 a.m. Overview of Subchapter C Acquisition and Reorganization Rules
9:45 a.m. Refreshment Break
10:00 a.m. Section 367(a): Asset Transfers
11:00 a.m. Corporate Reorganizations: Final Section 367(b) Regulations
12:00 p.m. Luncheon
1:00 p.m. Section 367(a): Stock Transfers
2:15 p.m. Section 367(d): Transfer of Intangibles
3:45 p.m. Current Developments in International M&A
5:00 p.m. Questions & Answers
5:15 p.m. Meeting Adjourns
Day Two
7:30 a.m. Continental Breakfast
8:30 a.m. Sections 355 and 367(e)(1)
9:15 am Refreshment Break
9:30 a.m. Internal Restructuring: Section 304 Issues
12:15 p.m. Luncheon
10:45 a.m. Taxable Acquisitions and Dispositions of Foreign Corporations
12:00 p.m. Luncheon
1:00 pm Taxable Aspects of International Acquisitions & Reorganization
367[b]
Regulations on Earnings & Profits on Foreign Income Tax Carryover
2:15 p.m. Questions & Answers
2:30 p.m. Seminar Concludes
CITE Conference Registration - Page 1
There are 3 ways to register for a CITE Conference:
- Complete this form and fax Page 2 to 914-328-5757
- Call us directly at 914-328-5656
- Complete the online registration process