A potential acquirer is often interested in using its stock to purchase a certain portion of a US target's businesses. In this circumstance, the acquisition commonly employs the so-called "Morris Trust" structure. In such a structure, the target corporation first distributes the stock of a controlled subsidiary (which would typically hold all of the target's "unwanted" businesses) to its shareholders, and then, holding only the desired business, the target corporation is acquired for stock by the acquiring corporation.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The OECD profile signals Brazil is no longer a jurisdiction where TP can be treated as a mechanical compliance exercise, one expert suggests, though another highlights “significant concerns”
Libya’s often-overlooked stamp duty can halt payments and freeze contracts, making this quiet tax a decisive hurdle for foreign investors to clear, writes Salaheddin El Busefi
The Clifford Chance and Hyatt cases collectively confirm a fundamental principle of international tax law: permanent establishment is a concept based on physical and territorial presence
The US president has softened his stance on tariffs over Greenland; in other news, a partner from Osborne Clarke has won a High Court appeal against the Solicitors Regulation Authority
Hany Elnaggar examines how AI is reshaping tax administration across the Gulf Cooperation Council, transforming the taxpayer experience from periodic reporting to continuous compliance