On July 18, 2023, Davis Polk partner Corey Goodman and counsel Aliza Slansky will be among the speakers at the Practising Law Institute’s “Basics of International Taxation 2023” program. Corey, who is serving as co-chairperson of the event, will give opening remarks and will speak on the “Considerations in Structuring Outbound Investments by U.S. Persons” panel. Topics discussed will include how to evaluate whether to operate directly or through a branch or separate entity, apply the outbound nonrecognition rules when transferring assets or stock of existing businesses to a foreign corporation, and assess the potential impact of anti-inversion rules.

Aliza is speaking on the “Taxation of Foreign Income: U.S. Shareholders in Controlled Foreign Corporations” panel, which will discuss how to classify a foreign corporation as a controlled foreign corporation, evaluate the global intangible low-taxed income and Subpart F regimes, and summarize the downward attribution rules as applied to CFCs.

For more information, please visit the event website.

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