There is a natural tension between buyers and sellers in M&A transactions. Buyers want to deduct the purchase price as soon as possible, and sellers want to maximize the after-tax proceeds. However, these transactions also involve a myriad of other considerations, including the impact of the corporate tax residence rules and the controlled foreign company rules.

In this Bottom Line videocast, Eversheds Sutherland (US) Partner Daniel Nicholas See more +

There is a natural tension between buyers and sellers in M&A transactions. Buyers want to deduct the purchase price as soon as possible, and sellers want to maximize the after-tax proceeds. However, these transactions also involve a myriad of other considerations, including the impact of the corporate tax residence rules and the controlled foreign company rules.

In this Bottom Line videocast, Eversheds Sutherland (US) Partner Daniel Nicholas and Eversheds Sutherland (International) Partner David Jervis discuss:

buyer and seller incentives

tax due diligence/pre-closing considerations

the corporate tax residence rules and the controlled foreign company rules See less -