Crossing Borders focuses on critical tax issues related to international acquisitions. Topics include tax planning matters, corporate structuring, foreign affiliate rules, tax treaties, financing, transfer pricing, supply chain, business valuations, risk assessment, due diligence steps, tax anti-avoidance, bilateral investment treaties and selected financial accounting matters. Selected legislative examples and court cases from various jurisdictions and the EU, and analysis from the OECD and the UN are used for illustrative purposes. Rather than a monothematic approach focusing only on tax issues, the goal of this book is to take an alpha-to-omega approach to cross border investments relevant for both global tax and business professionals and decision-makers. The analysis goes beyond core tax matters and addresses the multiple disciplines that interact with tax, and vice versa.
- New chapter on supply chain matters and structuring to combine acquirer and target to achieve business and tax efficiencies.
- New chapter on post-acquisition steps and considerations.
- Selected transfer pricing cases highlighting particular challenges.
- Indirect changes in ownership and related tax issues.
- Recent OECD and UN developments and challenges to tax planning.
- Increasing challenges on the utilization of debt for financing.
- Further developments in the ever-increasing area of anti-avoidance.