The Resource Earn-outs in cross border acquisitions : managing Code Sec. 956 exposure

Earn-outs in cross border acquisitions : managing Code Sec. 956 exposure

Label
Earn-outs in cross border acquisitions : managing Code Sec. 956 exposure
Title
Earn-outs in cross border acquisitions : managing Code Sec. 956 exposure
Creator
Subject
Language
eng
Summary
Earn-outs are quite common in acquisition transactions but when an earn-out is secured by a CFC stock pledge or guarantee, complexities will arise under Subpart F that can be difficult to navigate. While the discussion in this article highlights some of these complexities in the context of earn-outs, the principles also apply where a CFC stock pledge or guarantee is used to secure other contingent obligations of a U.S. person. It is critical for taxpayers to understand the implications of these rules in the context of contingent payment obligations in order to minimize or avoid income inclusions under Subpart F
Citation source
In: International tax journal. - Chicago. - Vol. 42 (2016),
http://library.link/vocab/creatorName
  • Harty, S.A
  • Richman, S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • cross-border acquisition
  • CFC
  • Subpart F income
Label
Earn-outs in cross border acquisitions : managing Code Sec. 956 exposure
Instantiates
Publication
Label
Earn-outs in cross border acquisitions : managing Code Sec. 956 exposure
Publication

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