Archives: Section 7874 inversions

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Happy Holidays To Our Readers!

As we reflect on 2015, we are especially thankful for all of the connections that we have made this year. We are thankful for our clients, our colleagues, our friends, and all of our readers. Thus, for our holiday video we wanted to focus on the power of relationships because our relationships are the foundation … Continue Reading

A Digital Encyclopedia: Bilzin Sumberg’s Blogosphere

Bilzin Sumberg prides itself as being the go-to firm for domestic and international investors and corporations doing business in Florida and beyond. We aim to provide our clients with legal and business insight into the industries and areas they work in through our various blogs, which hone in on key issues or areas of interest … Continue Reading

Ruling Demonstrates Potential for Inversion Rules to Apply in Inbound Structures

In Private Letter Ruling 201432002 (the “PLR”), the IRS ruled that a foreign-to-foreign “F” reorganization did not implicate the Section 7874 anti-inversion rules.  As a result, a foreign corporation (that was 100 percent foreign owned) was not deemed to be a U.S. corporation for U.S. federal income tax purposes, despite the fact that it was … Continue Reading

10th Annual University of Florida International Tax Symposium

On Friday, October 31, I will be speaking at the 10th Annual University of Florida International Tax Symposium held at the University of Florida, Levin College of Law in Gainesville, Florida. I, along with the other speakers, will discuss important topics revolving around current and future international tax policy. The presentation will begin at 8:00 am in … Continue Reading

American Bar Association Business Law Section Annual Meeting

On Thursday, September 11, I will be speaking at the inaugural American Bar Association – New Business Law Section Annual Meeting in Chicago, Illinois. The ABA Business Law Section Annual Meeting is being held from September 11-13 and is ideal for professionals that want to experience an all-inclusive business law programming event. The entirety of … Continue Reading

The Real Tax Benefits of Inverting to Canada

On August 26, Burger King announced that it entered into an agreement to acquire Tim Hortons, Inc., the Canadian coffee-and-doughnut chain, in a transaction that will be structured as an “inversion” (i.e., Burger King will become a subsidiary of a Canadian parent corporation).  The deal is expected to close in 2014 or 2015. The agreement values … Continue Reading

Inbound U.S. Tax Planning With Inversions

With all of the recent negative publicity focused on the outbound restructuring of U.S. multinationals engaging in so-called “inversion” transactions (see prior blog “Corporate Inversions Showing No Signs of Slowing Down”), little, if any attention, has focused on the potential tax planning opportunities available in the inbound area resulting from the (likely unintended) consequences of … Continue Reading

The NYU Summer Institute in Taxation Conference

On Tuesday, July 15, I will be speaking at an NYU School of Continuing Education conference in New York, NY. The Summer Institute in Taxation program is being held from July 14-25 and is ideal for new professionals that want a solid foundation in a specialized area of law or tax practice. Attorneys and accountants … Continue Reading

Corporate Inversions Showing No Signs of Slowing Down

In a corporate inversion, a U.S. corporation (typically the parent of an affiliated group) becomes a wholly owned subsidiary of a foreign corporation (through a merger into the foreign corporation’s U.S. subsidiary) or transfers its assets to the foreign corporation, but at the same time keeps most of its operations in the United States. Inversions … Continue Reading

Bloomberg BNA’s U.S. International Reporting & Compliance Seminar

On Tuesday, May 20th, I will be speaking at a seminar presented by Bloomberg BNA, entitled U.S. International Tax Reporting & Compliance. Held at the Marriot Biscayne Bay in Miami, the conference will also feature speakers from accounting firms Ernst & Young, KPMG and PwC. I will be speaking on “Computing the Gain from the … Continue Reading
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