Sam Kaywood spoke on a panel discussion titled “International Mergers and Acquisitions: S Tax Considerations and Planning Techniques.” Among the topics covered in this session were 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 included planning in light of recent tax law changes, including the base erosion anti-abuse (BEAT) and new anti-hybrid deduction limitations.
Heather Ripley spoke at on a panel discussion titled “Foreign Persons Investing in U.S. Real Estate and other Assets: Partnerships and other Structures, Treaty Planning and Financing Strategies.” This session addressed 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 those for interests in publicly traded companies, and domestically controlled real estate investment trusts. Special exemptions for qualified pension investors and foreign sovereign investors, and treaty and other withholding tax exemptions for payments of interest to foreign investors were also discussed.
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