Tax-Efficient Strategies
Leveraged Partnership
A leveraged partnership structure allows a seller to transfer most of the economic interest in a business in exchange for cash without triggering current...
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Like-Kind Exchange
A like-kind exchange allows two parties to exchange discrete tangible assets (i.e. PP&E and real estate) of a similar character in a tax-free transaction.
...
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Mixing Bowl
While corporations can exchange discrete assets of a similar character in a tax-free "like-kind" exchange, they cannot generally exchange businesses...
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Monetizing Spin-Off
A monetizing spin-off is a structure which allows a Seller to spin off a subsidiary on a fully tax-free basis while de-leveraging to a very significant...
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Sponsored Spin-Off
The sponsored spin-off has drawn increasing attention from the private equity community as a tax-efficient technique to acquire a substantial interest...
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Double Reverse Morris Trust
Transaction Overview
The double reverse Morris Trust structure is relevant for several scenarios:
Two public companies with divisions, which...
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Supercharged IPO
Transaction Structure
Step 1
Description
Seller owns subsidiary which it seeks to montetize through "supercharged IPO"
Step...
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JV IPO
Overview
A JV IPO transaction is a structure whereby two companies for a joint venture, which can be subsequently monetized via an IPO
The joint...
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Cash-Rich Split-Off
Overview
A cash-rich split-off is an M&A technique whereby the Seller exchanges stock of the Company for stock of a "cash-rich" subsidiary of...
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