Need Tax Help for Your Multinational Business?
If you run an international or multinational business, whether it’s based in the United States or abroad, then you know the different intricacies that this situation can involve. Not only do you have to consider all the business and tax laws for the country in which you are based, but you also have to be attentive to all those same things in the other countries in which you operate.
At Greenstein Rogoff Olsen and Co LLP, we understand the different risks and challenges that you are faced with and we have more than 15 years of experience dealing with international and multinational companies. In fact, GROCO is a member of the MSI Global Alliance, which is a Top 20 ranked, leading international association of independent professional firms.
GROCO also has legal and accounting partners in virtually every foreign market. That means we can help you lower your effective tax rate worldwide. These are a just a few of the issues we can help you with.
- Selecting the right holding company
- VAT and GST considerations
- US compliance
- Cross-boarders mergers and acquisitions
- Expanding outside or into the U.S.
To learn more about our international and multinational tax services click here. You can also contact us at 1-877-CPA-2006, or by clicking here.
Details of Patterns of Reorganization
Details of Patterns of Reorganization • “A” Reorganization • “B” Reorganization • “C” Reorganization • “D” Reorganization • “E” Reorganization • “F” Reorganization • “G” Reorganization “A” Reorganization Type “A” Reorganization consists of • Merger • Consolidation Both involve the acquisition of one company’s assets by another. Merger Explanation: • Target transfers its assets and…
“B” Reorganization
“B” Reorganization Type “B” involves the acquisition of stock of one corporation by another, and the target corporation becomes a subsidiary of the acquiring, as a result. Requirements of “B” Reorganization 1) The acquisition must be one of a series of acquisitions that are part of an overall plan to acquire the requisite control. 2)…
“C” Reorganization
“C” Reorganization The target corporation must liquidate as part of the plan of reorganization unless the IRS waives this requirement.’ As a result, the shareholders of the target corporation become shareholders in the acquiring corporation. In determining the tax consequences to the liquidating target, the reorganization provisions govern-not the liquidation rules of §§ 336 and…
“D” Reorganization
“D” reorganization: “Spin-off” and “Split-off” acquisitive d reorganization “D” Reorganization Explanation: * Corporate T contains the assets of former corporation A and of T. * Corporation A goes out of existence Corporation A’s shareholder’s control Corporation T. Requirements for Divisive “D” d reorganization requirements imposed by IRC §355 * Distribution of Control -by the…