The Resource Planning for tax controversies before, during and after the deal : new dynamics in cross-border M&A under the TCJA

Planning for tax controversies before, during and after the deal : new dynamics in cross-border M&A under the TCJA

Label
Planning for tax controversies before, during and after the deal : new dynamics in cross-border M&A under the TCJA
Title
Planning for tax controversies before, during and after the deal : new dynamics in cross-border M&A under the TCJA
Creator
Subject
Language
eng
Summary
This article considers several of the Tax Cuts and Jobs Act (TCJA)'s changes in the context of crossborder M&A deal practice, focusing on how reform has altered certain deal dynamics and considerations. The article proceeds in four sections. First, this article sets up a basic deal example used for illustrative purposes throughout. Second, this article provides an overview of the general parameters and framework of a cross-border deal, discussing basic deal terms, negotiating points and considerations. Third, this article considers some of the new dynamics introduced by the TCJA and how commonly applicable aspects of cross-border M&A were altered as a result. Lastly, this article describes why the TCJA increased the number of situations in which post-closing actions can affect each of the parties and why the parties may expect to have more interaction post-closing than they would have had before reform
Citation source
In: International tax journal. - Riverwoods. - Vol. 45 (2019), no. 3 (May-June) ; p. 5-28, 77-78
http://library.link/vocab/creatorName
  • DeNovio, N.J
  • Fisher, M.L
  • Shashy, S.N
  • McCrain, E.P
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • tax reform
  • TCJA
  • merger
  • acquisition
  • withholding tax
  • BEAT
  • GILTI
  • tax return
  • audit
Label
Planning for tax controversies before, during and after the deal : new dynamics in cross-border M&A under the TCJA
Instantiates
Publication
Label
Planning for tax controversies before, during and after the deal : new dynamics in cross-border M&A under the TCJA
Publication

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