The Resource Hitting the sweet spot : U.S. and Canadian tax treatment of cross-border spinoffs

Hitting the sweet spot : U.S. and Canadian tax treatment of cross-border spinoffs

Label
Hitting the sweet spot : U.S. and Canadian tax treatment of cross-border spinoffs
Title
Hitting the sweet spot : U.S. and Canadian tax treatment of cross-border spinoffs
Creator
Subject
Language
eng
Summary
Both U.S. and Canadian tax laws provide for corporate spinoffs that are tax-free for either the distributing corporation or the distributee shareholders, or both, as long as specific requirements are met. These requirements are complicated enough in the purely domestic context, but in the cross-border context they can be downright bewildering. This article demystifies the major requirements in both the United States and Canada and describes how the two regimes may be combined in order to maximize the benefit under both countries' tax systems in cross-border spinoff transactions
Citation source
In: Tax notes international. - Falls Church. - Vol. 78 (2015),
http://library.link/vocab/creatorName
  • Gucciardo, F
  • Tejeda, A
  • Crouse, E
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • spin-off
  • cross-border transaction
  • butterfly reorganization
Label
Hitting the sweet spot : U.S. and Canadian tax treatment of cross-border spinoffs
Instantiates
Publication
Label
Hitting the sweet spot : U.S. and Canadian tax treatment of cross-border spinoffs
Publication

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      52.37366609999999 4.9336932
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