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If 7874(b) applies, the foreign acquirer will be treated as a domestic corporation for all U.S. tax purposes.
A crafty foreign acquirer, be it a blue-chip company or a buyout house, could help them expand abroad, far from Italy's travails and endemically weak growth.
Alternatively, Section 7874(b) applies if the foreign acquirer would be deemed to be a surrogate foreign corporation under subsection (a) and the 60% threshold in 7874(a)(2)(B)(ii) reaches 80%.
That should catch the eye of a potential foreign acquirer, previously restricted from ownership.
When a company is taken over by a foreign acquirer this usually triggers a lot of anxiety in the workforce.
Or is it a crying shame to see another of the crown jewels of UK technology sold to a foreign acquirer?
Similar(54)
To receive the benefits of a tax inversion, the acquiring foreign entity must be the right size relative to the acquirer.
Generally, inadequate price, concern for the fate of employees, and the foreign identity of the acquirer are recurring features that raise criticism.
Knowledge usually flows from the acquirer to the acquired.
In particular, we conclude that taxing foreign dividends plays a decisive role in determining the reservation price of an acquirer, whereas taxing capital gains seems irrelevant.
The "absorption" type is when the acquired organization is fully absorbed by and becomes a part of the acquirer.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com