There are numerous reasons to initiate corporate restructuring activities and, once started, such activities appear to be an ongoing process that never finds an end. For example, restructuring activities driven by business reasons only will often impose legal and, in particular, tax risks. Restructuring activities are often also driven by M&A activities as post-closing restructuring activities by the purchaser and/or pre-closing restructuring activities by the vendor. The increasing number of changes in tax legislation internationally questions previous restructuring activities and will often give cause to rethink previous decisions or initiate, from a strategic perspective, even new restructuring activities.

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