• videocam On-Demand Webinar
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

U.S. Tax Treatment of Hybrid Entities and Transactions: Sections 267A and 245A(e) Regulations

Navigating the Mismatches of U.S. and Foreign Tax Law, Key Planning Techniques for Tax Professionals

$347.00

This course is $0 with these passes:

CLE
CPE
ALL
  1. keyboard_arrow_leftBack

About the Course

Introduction

This CLE/CPE course will discuss U.S. tax law anti-hybrid rules and restrictions that may apply where U.S. and foreign tax law provide different characterizations of transaction or entity, including regulations under Section 267A and Section 245A(e).

Description

The 2017 tax reform provided new anti-hybrid rules to address perceived abuse involving hybrid entities and transactions with related foreign parties. In April 2020, the IRS issued final and proposed regulations under sections 245A(e) and 267A. Tax counsel and advisers must navigate the new regulations' nuances and restrictions in international tax planning.

Section 267A denies a deduction for interest and royalties paid by a U.S. taxpayer to a related foreign party in certain situations, including when there is (1) a double-nontaxation outcome, (2) a double deduction outcome, or (3) a deduction/non-inclusion outcome.

Section 245A(e) addresses hybrid dividends received by a U.S. shareholder from a controlled foreign corporation (CFC). When applied, this provision denies a deduction for dividends received, treats similar amounts received by a CFC as subpart F income, and denies any foreign tax credit.

Listen as our panel discusses key provisions of the new regulations, new anti-hybrid restrictions, and key planning techniques for tax counsel and advisers.

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • CPE credit is not available on recordings.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).


  • Live Online


    On Demand

Date + Time

  • event

    Thursday, March 25, 2021

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. Overview of reasons for new rules
  2. Overview of anti-hybrid regulations under Sec. 267A and Sec. 245A
  3. Impact of the new regulations

The panel will review these and other key issues:

  • What are the key provisions of recent IRS regulations for hybrid entities and transactions?
  • What are the key tax considerations impacting international tax planning?
  • What are hybrid deduction accounts and how do they impact a taxpayer’s dividends-received deduction under section 245A?
  • What taxpayer relief is provided under the final regulations?

Learning Objectives

After completing this course, you will be able to:

  • Identify key provisions of recent IRS regulations for hybrid entities and transactions
  • Understand the impact of the new rules on international tax planning
  • Understand the special rules for hybrid deductions under the section 245A dividends-received deduction
  • Recognize the tax pitfalls of hybrid transactions and methods to avoid them
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Two years+ business or public firm experience at mid-level within the organization, supervising other preparers/accountants, preparing complex individual tax forms and schedules. Familiarity with concepts of cross-border tax arbitrage and hybrid entities.

BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .