The Resource Select cross-border tax issues in Reverse Morris Trust transactions

Select cross-border tax issues in Reverse Morris Trust transactions

Label
Select cross-border tax issues in Reverse Morris Trust transactions
Title
Select cross-border tax issues in Reverse Morris Trust transactions
Creator
Subject
Language
eng
Summary
The tax press in recent years has focused considerable attention on certain types of transactions, with socalled inversion transactions high on that list. In addition, related party financings subject to new Code Sec. 385 regulations, which ultimately had their origins in the context of concerns over inversion transactions, have also been an area of significant focus in the last year. Those regulations were proposed in broad fashion and have recently been finalized with a more inversion/inbound focus. Another significant area of activity are triangular reorganization restructurings that have repatriation aspects. Sharing the stage with these transactions is a separate category of transactions that have been increasingly popular in recent years - so-called Reverse Morris Trust or RMT transactions. An RMT transaction is a divestiture transaction, combined with an acquisition of the divested corporation, in which the distributing corporation creates in a tax-efficient manner two more "pure play" business enterprises that benefit each enterprise. This article reviews the relevant law generally and focuses on certain U.S. federal income tax issues that can arise in the cross-border context of RMT transactions
Citation source
In: International tax journal. - Riverwoods. - Vol. 43 (2017), no. 6 (November-December) ; p. 5-23, 52-53
http://library.link/vocab/creatorName
  • Hicks, H
  • Levere, D
  • Stevenson, R.C
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • inversion transaction
  • trust
  • triangular reorganization
Label
Select cross-border tax issues in Reverse Morris Trust transactions
Instantiates
Publication
Label
Select cross-border tax issues in Reverse Morris Trust transactions
Publication

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