Sam Kaywood and Heather Ripley will speak at this program hosted by the NYU School of Professional Studies.
Sam Kaywood will serve as a panelist for the session “International Mergers and Acquisitions: U.S. Tax Considerations and Planning Techniques.” Among the topics covered in this session are the U.S. tax considerations for taxable and tax-free stock acquisitions of foreign companies, CFC issues, tax-free acquisitions of U.S. companies, planning for the use of holding companies, inversion transactions, debt-equity regulations, use of hybrid instruments, OECD BEPS issues, and recent developments. The session also includes planning in light of recent tax law changes, including the base erosion anti-abuse tax (BEAT) and new anti-hybrid deduction limitations.
Heather Ripley will serve as a panelist for the session “Foreign Persons Investing in U.S. Real Estate and Other Assets: Partnership and Other Structures, Treaty Planning, and Financing Strategies.” This session addresses the definition of U.S. real property interest; tax rules applicable to foreign persons disposing of U.S. real property interests; special rules applicable to investments through real estate investment trusts; special exceptions, including for interests in publicly traded companies and domestically controlled real estate investment trusts, as well as special exemptions for qualified pension investors and foreign sovereign investors; and treaty and other withholding tax exemptions for payments of interest to foreign investors.
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