This document is a draft report by PricewaterhouseCoopers LLP for JMWT LLC regarding the tax structuring of the proposed acquisition of Phaidon Press Ltd and its subsidiaries. It outlines a strawman structure for the acquisition, focusing on tax efficiency and flexibility in financing through debt and equity. The report includes objectives such as tax-efficient offset of interest costs, flexibility for investment, and tax-efficient repatriation of profits. It also discusses the potential for a Section 338g election for US tax purposes and the implications of UK transfer pricing rules.
documents/EFTA00611186.pdf
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