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.
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Pillar two might be top of mind for many multinational companies, but the huge variations between countries’ readiness means getting ahead of the game now, argues Russell Gammon, chief solutions officer at Tax Systems.