Heather will speak on the panel “FIRPTA Rules Applicable to Foreign Persons Investing in U.S. Real Estate."
This session will cover the definition of US real property interest, tax rules applicable to foreign persons disposing of US 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.
Sam will speak on the panel "International Mergers and Acquisitions: U.S. Tax Considerations and Planning Techniques."
This session will discuss the US tax considerations for taxable and tax- free stock acquisitions of foreign companies, CFC issues, tax-free acquisitions of US 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 tax law changes from the TCJA, including the base erosion anti-abuse tax (BEAT) and the anti-hybrid deduction limitations.
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