Foreign acquisition of a U.S. target group and subsequent restructuring

The foreign acquisition of a US target corporation and the inevitable post-acquisition restructuring bring into play a series of US tax rules covering a broad range of international tax matters. This article covers these tax rules, discusses the basic underpinnings of US tax law in this area, points out some of the more significant areas of which one should be aware when making the acquisition, and makes recommendations to eliminate some of the problems associated with the efforts to restructure the group after the acquisition.