Cross-Border M&A Planning and Developments

Tax attorney Joshua Odintz will participate in the Practising Law Institute's (PLI) 2026 International Tax Issues workshop. The program will explore how U.S. and global efforts to amend approaches to cross-border income have generated uncertainty for companies and heightened the risk for double taxation; it will review U.S. and international tax developments that affect large multinationals, small businesses and investors alike, from the One Big Beautiful Bill Act (OBBBA) to the Organization for Economic Cooperation and Development's (OECD) Pillar Two plan. Mr. Odintz will join a panel explaining how recent changes in U.S. tax law affect global transaction planning, in particular mergers and acquisitions (M&A). He will identify previously taxed earning and profits (PTEP) issues in M&A transactions, examine what Pillar Two means for these deals, and highlight technical rules that can result in deemed acquisitions and inflated domestic corporation shareholder's ownership percentages – both of which provoke Section 7874 application.