The Final and Proposed Section 245A Regulations

Level: Intermediate
Runtime: 93 minutes
Recorded Date: November 19, 2020
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  • Final extraordinary reduction rule
  • Final disqualified basis rule (GILTI) and extraordinary disposition rule (Participation Exemption)
  • Anti-Abuse rules
  • Proposed coordination rules
Runtime: 1 hour, 33 minutes
Recorded: November 19, 2020


Our panelists will discuss the recently published final and proposed section 245A regulations including a discussion on changes from the temporary rules on extraordinary dispositions and extraordinary reductions as well as the proposed coordination rules.

This program was recorded on November 19th, 2020.

Provided By

American Bar Association


Jim Wang

U.S. Department of the Treasury

Jim Wang has been an Attorney-Advisor at the US Department tof the Treasury since 2018 where he focuses his practice on international tax matters in the Office of Tax Policy.

Jim earned his JD at Harvard Law School and his Maters of Laws at Georgetown University Law Center.

Joshua Ruland


Joshua Ruland is a Principal at EY. He advises clients on all aspects of US international and partnership taxation, particularly cross-border acquisitions, dispositions, joint ventures and restructurings.

Joshua earned his JD at the University of Michigan Law School

Rachel Kleinberg

Sidley Austin LLP

Rachel Kleinberg is a tax partner in Sidley’s Palo Alto office. Her practice covers the U.S. federal tax aspects of a wide array of transactional matters, including M&A and private equity transactions, joint ventures, spinoffs and reorganizations, capital markets transactions, credit facilities, international tax matters and derivatives transactions.

Rachel has been acknowledged in numerous industry publications. She has been ranked Band 1 of Chambers USA in 2019 and 2020 as a leading lawyer in tax for Northern California. She is also recommended in The U.S. Legal 500 for International Tax and Financial Products (2019). Rachel was featured as one of the Women in Tax Leaders by International Tax Review (2015 – 2019) and named a “Tax MVP” by Law360 in 2019 for several notable transactions, including her representation of Brookfield Business Partners LP in its $13.2 billion acquisition of the power solutions business of Johnson Controls International.

Rachel is on the Advisory Board of the GW Law/IRS 33rd Annual Institute on Current Issues in International Taxation. She is also a frequent speaker on international and corporate tax topics at prestigious tax conferences, including leading panels at the University of Chicago Tax Conference, the USC Gould School of Law Tax Institute and PLI. She serves as chair of the Foreign Activities of U.S. Taxpayers Committee of the American Bar Association’s Section of Taxation and is a fellow of the American College of Tax Counsel.

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