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Product ID: 399674EAU
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Transfers of Tangible and Intangible Property to a Foreign Corporation

OnDemand Webinar (99 minutes)

Gain a better understanding of the reporting requirements of transfers to foreign corporations.U.S. corporations can transfer appreciated property in a wide variety of nonrecognition transactions such as reorganizations, capital contributions, and corporate liquidations. However, when such normal nonrecognition transactions result in transfer of property to a Foreign Corporation (FC), U.S. tax law imposes restrictions on the tax-free transfer of certain types of property by override of the normal nonrecognition rules. There is an override of the nonrecognition provisions because the gain on the appreciated property would permanently escape U.S. tax upon the outbound transfer of the property to the FC. Further, these rules give the IRS the authority to preserve their ability to impose U.S. income tax currently, or at a later time, on the accumulated E&P of certain foreign corporations. The purpose of this course will be to give participants an overview of the US outbound transfer of property to foreign corporations, discuss the mechanics, special transfer rules and creative strategies for dealing with US based appreciated property.


Ryan Gaglio, Baker & Hostetler LLP John P. Garcia, CPA, M.B.A., Corporate Tax Advisors


Overview of the U.S. Outbound Transfer Rules

• Purpose of the Rules

• When Outbound Transfers Receive Nonrecognition Treatment

• When Outbound Transfers Are Taxable

Mechanics of U.S. Outbound Transfers

• Terms and Acronyms

• Timely Compliance

• Exceptions to Filing

Special Transfer Rules

• Partnership

• Spouses

• Cash

• Stock or Securities for Which a Gain Recognition Agreement (GRA) Is Filed

• Distributions by Domestic Liquidating Corporations

Creative Strategies

• Worthless Stock Loss

• Pre-Acquisition Planning

• Transfer Pricing