Cross-Border Merger with US Public Company Target: US Tax Considerations | Practical Law

Cross-Border Merger with US Public Company Target: US Tax Considerations | Practical Law

An overview of the primary US tax considerations for a US public company target and its shareholders in a cross-border merger with a foreign acquiring company. This Note discusses common cross-border merger structures, all-cash mergers, mergers with mixed consideration, special tax-free reorganization rules applicable to cross-border transactions, and anti-inversion rules.

Cross-Border Merger with US Public Company Target: US Tax Considerations

Practical Law Practice Note w-028-0876 (Approx. 19 pages)

Cross-Border Merger with US Public Company Target: US Tax Considerations

by Practical Law Corporate & Securities
MaintainedUSA (National/Federal)
An overview of the primary US tax considerations for a US public company target and its shareholders in a cross-border merger with a foreign acquiring company. This Note discusses common cross-border merger structures, all-cash mergers, mergers with mixed consideration, special tax-free reorganization rules applicable to cross-border transactions, and anti-inversion rules.