Impact of Code Section 367 and the European Union's 1990 Council Directive on Tax-Free Cross-Border Mergers and Acquisitions

Authors

Samuel C. Thompson Jr., Penn State LawFollow

Document Type

Article

Publication Date

1-1-1998

First Paragraph

This Article examines the impact of (1) Internal Revenue Code section 3671 and the regulations thereunder,2 and (2) the European Union's (EU's) Council Directive on the Common System of Taxation Applicable to Mergers, Divisions, Transfers of Assets and Exchanges of Shares, Concerning Companies of Different Member States' on tax-free cross-border mergers and acquisitions.

Recommended Citation

Samuel C. Thompson Jr., Impact of Code Section 367 and the European Union's 1990 Council Directive on Tax-Free Cross-Border Mergers and Acquisitions, 66 U. Cin. L. Rev. 1193 (1998).