© 2007–2009 Cassels Brock Lorne Saltman American Bar Association Business Law Section Taxation Committee Canada/U.S. Cross Border M & A April 17, 2009.

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Presentation transcript:

© 2007–2009 Cassels Brock Lorne Saltman American Bar Association Business Law Section Taxation Committee Canada/U.S. Cross Border M & A April 17, 2009

© 2007–2009 Cassels Brock 2 Tax Consequences of Restructuring of Indebtedness Canadian Parentco Canadian Subco Loan

© 2007–2009 Cassels Brock 3 Tax Consequences of Restructuring of Indebtedness Canadian Parentco Canadian Subco Loan Newco

© 2007–2009 Cassels Brock 4 Debt Parent Canadian Subsidiary Canadian Subsidiary Tax Losses New Canadian Subsidiary New Canadian Subsidiary and Equity Issue new lower fair market value Transfer of debt 1 wind up Tax Consequences of Restructuring of Indebtedness 3 Sale of shares and new note of Sub 2 Purchaser

© 2007–2009 Cassels Brock 2100 Scotia Plaza, 40 King Street West, Toronto, Canada M5H 3C2 Phone © 2007–2009 Cassels Brock & Blackwell LLP. Cassels Brock and the CB logo are registered trade-marks of Cassels Brock & Blackwell LLP. ™ Trade-mark of Cassels Brock & Blackwell LLP. All rights reserved.