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Capital reduction demergers

Reflections on demergers

Capital reduction demergers are rare, but they can play an important part in corporate tax planning

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CASES

Rental income disclosure was unprompted Ignorance of the law is an excuse Clear winner but costs reduced for other factors Company was not resident in the US for treaty purposes Collagen-based drink was a beauty product

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Rental income disclosure was unprompted Ignorance of the law is an excuse Clear winner but costs reduced for other factors Company was not resident in the US for treaty purposes Collagen-based drink was a beauty product

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