Feb 25, 2021 19:25
3 yrs ago
8 viewers *
English term
post-closing
English to Polish
Law/Patents
Law (general)
general
Post-closing of the Proposed Transaction and upon a disposition of the Target, the Client could be subject to the withholding taxes and filing requirements of FIRPTA if the Target is a USRPHC. We recommend further analysis to be completed to determine whether the Target is a USRPHC and obtaining a statement from the Target post-closing that it is not a USRPHC.
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Certain of the post-closing restructuring options being evaluated by the client could be impacted based on whether or not the Target is treated as a USRPHC, so further evaluation of this should be undertaken.
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If the US assets/subsidiaries are sold post-closing, the taxable gain from the sale could potentially be offset by NOLs due to the increased Section 382 limitation created by the NUBIG.
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Certain of the post-closing restructuring options being evaluated by the client could be impacted based on whether or not the Target is treated as a USRPHC, so further evaluation of this should be undertaken.
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If the US assets/subsidiaries are sold post-closing, the taxable gain from the sale could potentially be offset by NOLs due to the increased Section 382 limitation created by the NUBIG.
Proposed translations
(Polish)
3 +1 | po zamknięciu transakcji | legato |
Proposed translations
+1
15 mins
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