DescriptionDeadly D Pseudo-reorganization acquisition diagram.png
English: This file represents a "Deadly D" pseudo-reorganization acquisition (PRA). In this PRA, a foreign subsidiary of a U.S. firm has trapped cash. The U.S. parent of the subsidiary acquires a second U.S. company using cash. Then, the U.S. parent transfers ownership to the subsidiary by swapping the subsidiary's cash for the stock of the acquired firm. This allows the "trapped cash" to effectively be brought into the United States without paying a repatriation tax.
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