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Some time ago I co-owned a Danish company (Company A).
We organized it so the owners actually all had shares in a single holding company (Company B) that then owned the shares in Company A.
Eventually we sold our shares in Company A to a buyer (Company C) in exchanges for shares in that company.
So, the resulting structure was: I owned some shares in Company B, which owned shares in Company C.
Since then I have become a Permanent Resident in the U.S.
We now wish to break-apart Company B, assigning each person's shares in Company C directly to the individuals. i.e. Company B will buy back Company B shares in return for Company C shares, then close.
All these companies are Danish.
Are there any U.S. tax implications of this restructuring, or only when an actual cash profit is realized (when/if I ultimately sell the Company C shares).
Thanks,
Russell.
We organized it so the owners actually all had shares in a single holding company (Company B) that then owned the shares in Company A.
Eventually we sold our shares in Company A to a buyer (Company C) in exchanges for shares in that company.
So, the resulting structure was: I owned some shares in Company B, which owned shares in Company C.
Since then I have become a Permanent Resident in the U.S.
We now wish to break-apart Company B, assigning each person's shares in Company C directly to the individuals. i.e. Company B will buy back Company B shares in return for Company C shares, then close.
All these companies are Danish.
Are there any U.S. tax implications of this restructuring, or only when an actual cash profit is realized (when/if I ultimately sell the Company C shares).
Thanks,
Russell.