The Resource Select corporate migration and combination considerations in an ever changing environment

Select corporate migration and combination considerations in an ever changing environment

Label
Select corporate migration and combination considerations in an ever changing environment
Title
Select corporate migration and combination considerations in an ever changing environment
Creator
Subject
Language
eng
Summary
The world of corporate migrations, "inversions" and other cross-border combinations has involved an ongoing and evolving landscape of transaction structures, statutory provisions and regulatory and other guidance. There have been significant developments in this area just in the last few years. This paper highlights some key developments in this area since that time. It is not intended as a comprehensive study or policy piece. In addressing more recent developments, it is helpful to review some of the relevant history. The current transactional trend is the focus on combination migration transactions where a US corporation is combined with an unrelated corporation under a new foreign parent corporation. This paper first reviews at a high level the basic rules in this area. It then discusses in more detail some key guidance and then addresses three transactional areas - self migrations, avoiding or minimizing the Code Sec. 367(a) tax and combination migrations
Citation source
In: International tax journal. - Chicago. - Vol. 40 (2014), no. 3 (May-June) ; p. 21-38
http://library.link/vocab/creatorName
  • Hicks, H
  • James, O
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • migration
  • inversion transaction
  • corporate inversion
Label
Select corporate migration and combination considerations in an ever changing environment
Instantiates
Publication
Label
Select corporate migration and combination considerations in an ever changing environment
Publication

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