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On Demand Premiere The Restructuring Lawyer’s Guide To Tax / Cross Border and Multi-jurisdictional Tax Issues
This webinar focuses on tax consequences for businesses with operations or income both in the United States and outside the United States or other multi-jurisdictional transactions. The panel describes the impact of the US tax rules on foreign corporations operating in the United States and partnerships with foreign partners. It also discusses how US tax rules affect US-owned foreign corporations that operate outside the United States. The panel examines how the cancellation of indebtedness and other rules apply to a controlled foreign corporation. It also examines how the cancellation of indebtedness and other rules apply to US owners of foreign corporations that are neither controlled foreign corporations nor passive foreign investment companies. Participants will learn about the US tax issues encountered by a foreign lender that modifies the debt of a US person. They will also learn the US tax consequences of a foreign lender that converts the debt of a US person into equity.