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.
Gregor McMillan of Howden explains how insurance-backed financing can help businesses and funds unlock liquidity from tax receivables and other contingent claims
The big four firm has been embroiled in a scandal over partners’ misuse of confidential board papers to pitch for and win corporate audits for Westpac and Dexus
Drawing on lessons from the PepsiCo case, tax lawyer Paul McNab explains why the ATO's latest royalty guidance should concern multinationals well beyond the technology sector
As pillar two exposes the limits of fragmented tax processes, organisations are rethinking their operating models to create the trusted data foundations that AI demands