Tag Archive for Section 355

Divisive Foreign Corporate Reorganizations

TaxConnections Picture - Corporate Buildings

Corporate reorganizations are valued tools to the practitioner. They provide the opportunity to defer taxable events by virtue of non-recognition treatment. They are characterized as acquisitive, reformative, and divisive transactions. Currently they are relevant as timely transactions as publicly traded security prices have soared while revenue growth has slowed. Companies can grow by shrinking, selling off under performing assets and putting the cash to work. (See Jack Hough, Buy the Asset Sellers, Barron’s Magazine, Saturday, December 7, 2013)

In a previous writing (Tax Connections/Foreign Corporate Acquisitive Reorganizations) the Read more