The acquisition or divestment of an entity (or a group of entities) can potentially give rise to income tax issues spanning almost the entire gambit of the income tax legislation. This presentation provides an overview of a number of current taxation issues in MAmp;A, with a focus on
- acquisition structuring issues (i.e. debt / equity mix, and other structuring considerations)
- some recently noted acquisition diligence issues (such as availability of clear exits, RTFI,and employment taxes)
- transaction documentation (including a discussion of industry best practice in relation to taxation warranties and indemnities).