Andersen Managing Directors Joe Calianno and Sean Dokko are presenting on international tax topics at New York University’s Summer Institute on Taxation, July 20-31, 2026, at the Westin New York at Times Square.
On July 22, as part of the Introduction to International Taxation program, for the session Cross-Border Transfers and Corporate Inversions, Joe will discuss how the rules of Internal Revenue Code Secs. 367 and 7874 curb the ability of U.S. taxpayers to transfer assets to, or to receive assets from, foreign corporations in transactions that would otherwise qualify as tax-free and prevent U.S. business entities from inverting to become foreign-owned.
On July 23, as part of the Advanced International Taxation program, for the session Controlled Foreign Corporation Planning: What’s New After OB3?, Joe and Sean will address how changes made under the One Big Beautiful Bill Act of 2025 to the U.S. tax treatment of U.S. shareholders of controlled foreign corporations (CFCs) affect planning opportunities and create traps for the unwary.