Cross-Border Acquisitions: Structuring Acquisitions, Section 7874 Inversion Rules, Section 338(g) Elections, GRAs

Hosted By: Strafford

This webinar will discuss tax consequences of cross-border transactions. Fenwick partner Will Skinner is speaking on a panel of foreign planning professionals that will discuss outbound transfers, foreign acquisitions and section 338(g) elections, and section 7874 inversion transaction.

  • Discussion on sections 367(a) and 367(b) pertain to the tax consequences of certain transactions involving the transfer of property by a U.S. person to a foreign corporation.
  • Discussion on section 338(g) election which allows the buyer to treat a stock purchase as an asset purchase and allows for a basis step-up for assets purchased.
  • Discussion on section 7874 transaction in which a domestic corporation or partnership converts into, merges with, or becomes a subsidiary of a foreign corporation through a stock exchange. Section 7874 transactions may result in adverse federal income tax implications. The severity of these tax consequences, amongst other factors, generally hinges on the extent of ownership overlap between the domestic entity before the transaction and the foreign corporation holding its stock or assets afterward.


There are limited number of free registrations available on a first come first serve basis. To inquire regarding availability please reach out to Jennifer Duret Khaleghi.