Weil Tax BLOG - Feed https://tax.weil.com/category/ma-cross-border/ Views and developments from the Tax Department at Weil Tue, 14 Apr 2026 20:54:30 +0000 hourly 1 Chambers Expert Focus Weil Tax Insight Series: U.S. Tax Legislative Update https://tax.weil.com/insights/chambers-expert-focus-weil-tax-insight-series-us-tax-legislative-updatechambers-expert-focus-weil-tax-insight-series/ Tue, 17 Oct 2023 13:17:41 +0000 Joseph Pari Devon Bodoh https://tax.weil.com/?p=2020 In this Chambers Expert Focus Weil Tax Insight Series podcast, Tax Co-Chair Joe Pari and International Tax Head Devon Bodoh discuss recent developments in tax aspects relating to M&A including debt exchanges, OECD’s implementation of Pillar Two, treaty qualification and tax insurance. Listen to the podcast here.

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]]> In this Chambers Expert Focus Weil Tax Insight Series podcast, Tax Co-Chair Joe Pari and International Tax Head Devon Bodoh discuss recent developments in tax aspects relating to M&A including debt exchanges, OECD’s implementation of Pillar Two, treaty qualification and tax insurance. Listen to the podcast here.

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]]> Brexit & Tax Treaties: U.K. Investors May Lose Treaty Benefits With Respect to U.S. Investments https://tax.weil.com/uk-tax/brexit-tax-treaties-u-k-investors-may-lose-treaty-benefits-with-respect-to-u-s-investments/ Fri, 04 Dec 2020 21:32:28 +0000 Devon Bodoh Stuart Pibworth http://tax.weil.com/?p=1115 The withdrawal of the United Kingdom (“U.K.”) from the European Union (“E.U.”) may impact certain cross-border organizational structures. We have previously considered some of those U.K. tax impacts in our post “Brexit and Tax: An Uncertain Future”. The points considered in that previous post continue to be relevant to cross-border structures involving the U.K. and

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]]> Accurate Drafting of Tax Warranties and Indemnities: Nuts and Bolts https://tax.weil.com/uk-tax/accurate-drafting-of-tax-warranties-and-indemnities/ Thu, 05 Dec 2019 10:27:28 +0000 Stuart Pibworth http://tax.weil.com/?p=775 Key points A mergers and acquisition document will extend beyond the transaction concerned The importance of contractual drafting was highlighted in the Minera Las Bambas case The contracts were governed by English law An indemnity against the full amount of adversely determined tax matters The sellers argued that tax became payable only when an enforceable

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]]> Key points A mergers and acquisition document will extend beyond the transaction concerned The importance of contractual drafting was highlighted in the Minera Las Bambas case The contracts were governed by English law An indemnity against the full amount of adversely determined tax matters The sellers argued that tax became payable only when an enforceable

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]]> US Tax Reforms: Impact on Cross-border Investments https://tax.weil.com/latest-thinking/us-tax-reforms-impact-on-cross-border-investments/ Wed, 12 Dec 2018 13:39:23 +0000 Robert Frastai Glenn D. West Weil Tax Blog http://tax.weil.com/?p=96 The US Tax Cuts and Jobs Act of 2017 (2017 Act), generally effective for tax years beginning after 31 December 2017, enacted sweeping reforms to the system of US federal income taxation of cross-border investments. The focus of the reforms on cross-border taxation is, generally, on outbound investments by USheadquartered multinational companies and moves from

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]]> The US Tax Cuts and Jobs Act of 2017 (2017 Act), generally effective for tax years beginning after 31 December 2017, enacted sweeping reforms to the system of US federal income taxation of cross-border investments. The focus of the reforms on cross-border taxation is, generally, on outbound investments by USheadquartered multinational companies and moves from

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]]> Debt Waivers in Cross-border Restructuring: Problems With the UK’s Anti-hybrid Legislation https://tax.weil.com/uk-tax/straight-to-the-point/debt-waivers-in-cross-border-restructuring-problems-with-the-uks-anti-hybrid-legislation/ Mon, 01 Oct 2018 10:25:23 +0000 Weil Tax Blog http://tax.weil.com/?p=504 Recent changes to UK tax law appear to have resulted in a stealth increase to the number of situations in which a release of loans in cross-border restructuring scenarios can be taxable in the UK. The date on which a loan was entered into or drawn down now appears to have a material effect on

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]]> Recent changes to UK tax law appear to have resulted in a stealth increase to the number of situations in which a release of loans in cross-border restructuring scenarios can be taxable in the UK. The date on which a loan was entered into or drawn down now appears to have a material effect on

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]]> US Tax Reforms: Impact on Cross-border Investments https://tax.weil.com/uk-tax/straight-to-the-point/us-tax-reforms-impact-on-cross-border-investments-2/ Wed, 11 Jul 2018 09:36:56 +0000 Oliver Walker http://tax.weil.com/?p=498 The US Tax Cuts and Jobs Act of 2017 (2017 Act), generally effective for tax years beginning after 31 December 2017, enacted sweeping reforms to the system of US federal income taxation of cross-border investments. The focus of the reforms on cross-border taxation is, generally, on outbound investments by US headquartered multinational companies and moves

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]]> The US Tax Cuts and Jobs Act of 2017 (2017 Act), generally effective for tax years beginning after 31 December 2017, enacted sweeping reforms to the system of US federal income taxation of cross-border investments. The focus of the reforms on cross-border taxation is, generally, on outbound investments by US headquartered multinational companies and moves

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]]> M&A Tax Protections UK and US Market Practice https://tax.weil.com/uk-tax/straight-to-the-point/ma-tax-protections-uk-and-us-market-practice-3/ Thu, 25 Sep 2014 13:24:59 +0000 Oliver Walker Erica Rees http://tax.weil.com/?p=585 On large cross-border acquisitions of private companies, tax advisers often need to understand the prevailing market practice in multiple jurisdictions. While knowledge of the tax issues and how they are covered in the legal documents is key, it is also crucial to ensure that contractual provisions are not out of step with any accepted market

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]]> On large cross-border acquisitions of private companies, tax advisers often need to understand the prevailing market practice in multiple jurisdictions. While knowledge of the tax issues and how they are covered in the legal documents is key, it is also crucial to ensure that contractual provisions are not out of step with any accepted market

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