A key tax consideration is whether the acquirer will be entitled to a stepped up tax basis in the assets and thus entitled to future tax deductions.
Canada, like the U.S., imposes a thorough set of documentation requirements, and imposes penalties for failure to comply.
In the case of a U.S. acquisition of a foreign target, it was oftentimes beneficial to make a Section 338(g) election.
The impact of the investor model is that it essentially guarantees a return to the intangibles developer for its efforts.
In the original Practice Aid, there was no mention of the back-solve approach. Since then the technique has come into widespread use.
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