This session, from TEI’s 2025 International Tax Course, provides tax professionals with a comprehensive overview of the U.S. tax provisions governing international reorganizations and corporate inversions. Participants will examine the key rules, policy objectives, and practical implications of Sections 367 and 7874.
Learning Outcomes
- Understand the scope and purpose of Sections 367 and 7874, including the policy objectives behind these provisions.
- Analyze the tax implications of outbound transfers, mergers, and acquisitions under Section 367 and the anti-inversion provisions of Section 7874.
- Identify planning and compliance considerations for structuring international reorganizations while adhering to U.S. tax rules.
Who Should Attend
This session is designed for tax professionals involved in international tax matters, those transitioning to a new tax practice area within their company, or those taking on new responsibilities, including tax advisors, corporate tax professionals, CPAs, tax managers, and international tax lawyers. It will benefit professionals seeking a comprehensive understanding of the U.S. tax provisions governing international reorganizations and corporate inversions.
Instructor(s)
Brian Harvel, Partner, Alston & Bird LLP
General Session Information
Access
Online, upon completion of the checkout process, you will be directed to our Learning Management System (LMS) for access to the session.
For member pricing, please login to tei.org
This is a digital product. With full paid access, the content will be available for one year after the purchase date.
CPE Credits
This digital product is not eligible for Continuing Professional Education (CPE) credit and includes the recording from the 2025 in-person session and the corresponding PowerPoint slides.
Length of Session
The session will take approximately 2.0 hours to complete.
NASBA Field of Study
Taxes
Level
Basic
Prerequisites
None
For more information, please refer to CPE requirements and NASBA sponsorship information.
Terms & Conditions
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