DescriptionOutbound F Pseudo-reorganization acquisition diagram.png
English: This diagram is a visual representation of an "Outbound F" pseudo-reorganization acquisition (PRA). In this PRA, an existing foreign subsidiary of a U.S.-based multinational company has "trapped cash" that has not been repatriated. The multinational acquires another U.S. firm in an all-stock deal, then forces the newly acquired company to provide its new parent company with a note payable equal to the size of the acquisition's real cost. The multinational then creates a new foreign subsidiary, transfers to it the assets and liabilities of both the newly acquired U.S. firm and the foreign subsidiary with trapped cash. Finally, the newly created subsidiary repays the note payable that it had acquired when it absorbed the liabilities of the newly acquired U.S. firm with the trapped cash it had acquired when it absorbed the assets of the older foreign subsidiary. This allows for the acquisition to take place, and for the trapped cash to effectively be moved into the parent corporation, all without paying any repatriation taxes on that trapped cash.
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