USA Foreign Share Swap

[russellquinn]

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.