Are there any transaction structures that can be utilized by a US corporation to repatriate low-taxed offshore cash in the context of the acquisition of a target company?
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Tax Professional Answers
Chris Haunschild
There are several transaction structures that will permit a US corporation to repatriate low-taxed offshore cash in the context of the acquisition of a target company. These include:
• Outbound Forward Triangular Merger
• Outbound “A” Merger with Boot
• Outbound “F”
• Outbound “D”
• Non-Killer B Purchase of US Parent Stock
Please contact me for additional details on the mechanics and considerations for each of these transaction structures.
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628 weeks ago
• Outbound Forward Triangular Merger
• Outbound “A” Merger with Boot
• Outbound “F”
• Outbound “D”
• Non-Killer B Purchase of US Parent Stock
Please contact me for additional details on the mechanics and considerations for each of these transaction structures.