Legal entity restructuring and reorganisations

It was the best of times, it was the worst of times,” so starts Dickens’ timeless masterpiece, A Tale of Two Cities. For many C-Class executives, the current recession has certainly been the worst of times, at least in their business careers. However, as companies take a hard look at their current operating structures, both legally and functionally, it is the best of times to achieve not only operational efficiencies but also tax efficiencies. This article discusses and illustrates, through a case study, some of the tax benefits that can be achieved through restructurings for a corporation conducting business in more than one tax jurisdiction.
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