Recent developments in corporate and partnerships implications for transac

Recent developments in corporate and partnerships: implications for...
http://www.slideshare.net/ernstandyoung/recent-developments-in-corporate-and-partnerships-implications-for-transaction-planning[5/2/2013 9:10:59 AM]
Upload Browse Go PRO Login Signup
Email Like Save Embed
/41
Recent developments in corporate and partnerships:
implications for transaction planning
by Ernst & Young on May 01, 2013
11
views
This presentation covers the following topics relating to recent developments in corporate and partnership
planning: ...
More…
+ Follow
No comments yet Notes on Slide 1
More
Domestic cash tax planning:
minimizing cash tax payments
and maximizing cash tax…
12 views
Financial transactions: recent
developments and issues
37 views
Leading tax department change
12 views
How financial services
organizations are operating in a
dynamic regulatory envir…
15 views
Affordable Care Act: what Tax
Directors need to know
17 views
Current trends and evolving
issues in cross-border
transactions
14 views
Accounting for income taxes: hot
topics and developments
21 views
Tax provision process and
technology trends: why and how
to continually improve
17 views
Information reporting and
withholding: the impact of the
Foreign Account Tax Com…
9 views
IRS enforcement updates:
navigating the changing IRS
landscape
9 views
Tangible property regulations:
what to do now, what to do next
14 views
Service center compliance and
tax return reporting: recent
developments and issu…
10 views
State and local business tax
Submit Query
1
More…

Recent developments incorporate and partnershipp p pplanningDomestic Tax
ConferenceDomestic Tax ConferenceMay 1, 2013
Disclaimer► Ernst & Young refers to the global organization of member firms
ofErnst & Young Global Limited, each of which is a separate legalentity. Ernst
& Young LLP is a client-serving member firm ofentity. Ernst & Young LLP is
a client serving member firm ofErnst & Young Global Limited located in the
US.► This presentation is ©2013 Ernst & Young LLP. All rights reserved.No
part of this document may be reproduced, transmitted orp y potherwise
distributed in any form or by any means, electronic ormechanical, including by
photocopying, facsimile transmission,recording, rekeying or using any
information storage and retrievalsystem without written permission from Ernst
& Young LLP Anysystem, without written permission from Ernst & Young LLP.
Anyreproduction, transmission or distribution of this form or any of thematerial
herein is prohibited and is in violation of US andinternational law. Ernst &
Young and its member firms expresslyinternational law. Ernst & Young and its
member firms expresslydisclaim any liability in connection with use of this
presentation or itscontents by any third party.► The views expressed by
panelists in this webcast are notEighth Annual Domestic Tax Conference2p y
pnecessarily those of Ernst & Young LLP.
Circular 230 disclaimer► Any US tax advice contained herein was not
intended orwritten to be used and cannot be used for the purpose ofwritten to
be used, and cannot be used, for the purpose ofavoiding penalties that may
be imposed under the InternalRevenue Code or applicable state or local tax
lawprovisions.► These slides are for educational purposes only and arenot
intended and should not be relied upon asnot intended, and should not be
relied upon, asaccounting advice.Eighth Annual Domestic Tax Conference3
Todays presenters► Phillip Gall► Phillip Gall► Michael Kaibni► Brian
PeabodyF W► Franny WangEighth Annual Domestic Tax Conference4
Topics► Section 355 Monetization Strategies & New No-rule PolicyS ti 355 &
REIT El ti► Section 355 & REIT Election► Partnership IPO Structures►
Virtual Incorporations► Virtual Incorporations► Gone & Back Strategy► Key
Divestiture Tax Concepts and Complexitiesy p p► Chairman Camp’s Small
Business Tax Reform DraftProposalEighth Annual Domestic Tax Conference5
Section 355 Monetization Strategies & NewIRS No-rule PositionsEighth
Annual Domestic Tax Conference6
Background► A frequent objective in Section 355 transactions is to optimize
thecapital structures of the businesses of the distributing corporationcapital
structures of the businesses of the distributing corporation(“D”) and the
Recent developments in corporate and partnerships: implications for transaction
planning
Presentation Transcript
policy trends: will 2013 be a year
of dramatic stat…
9 views
Worldwide tax reporting in the
shared services age: seizing the
opportunity and …
13 views
Legislative, regulatory and
judicial income tax
developments: key states
18 views
Federal and state business
incentives and tax credits
16 views
EY Q1 2013 Financial Reporting
Update
90 views
Executing value creation plans
to maximize returns - 1 minute
recap
60 views
Executing value creation plans
to maximize returns
69 views
Video: The Affordable Care Act –
overview, regulatory
requirements and impleme…
85 views
The Affordable Care Act –
overview, regulatory
requirements and
implementation
137 views
The Ernst & Young Q4 2012
financial reporting update
195 views
Business Pulse - Dual
perspectives on the top 10 risks
and opportunities 2013 an…
2810 views
Looking beyond the obvious -
Globalization and new
opportunities for growth
196 views
Innovating for growth: Innovation
2.0 - A spiral approach to
business model inno…
195 views
Innovating for the next three
billion - The rise of the global
middle class and …
128 views
Paradigm shift - Building a new
talent management model to
boost growth
236 views

controlled corporation (“C”), providing each businesswith a capital structure
tailored to how it operates.► Another frequent objective is for a corporate
group to divest itself ofone or more lines of business in order to focus on a
core business (orbusiness) However D may want or need to receive
compensationbusiness). However, D may want or need to receive
compensationfor the divestiture but, for a variety of reasons, a sale of the
unwantedbusiness may not be possible or practical.Eighth Annual Domestic
Tax Conference7
General Methods► Generally, there are six methods by which the value
canbe extracted from a non-core business in connection withthe tax-free
separation of core and non-core operations.► Controlled Assumption of
Liabilities: assumption of liabilities of thedistributing corporation (D) by the
controlled corporation (C);distributing corporation (D) by the controlled
corporation (C);► Controlled Cash Distribution: distribution of C’s cash in
exchange forassets transferred by D;► Controlled Cash Purchase: C’s
purchase of D’s assets for cash;► Controlled Cash Purchase: C s purchase
of D s assets for cash;► Controlled Securities Exchange: exchange of C
securities (long-termdebt) for D debt;► Controlled Stock Exchange: exchange
of a portion of C stock for D debt;g g p ;and► Reverse Direction Spin-off:
leverage the non-core business and spin thecore business (together with the
proceeds of leveraging)Eighth Annual Domestic Tax Conference8
Controlled Assumption of Liabilities andDistribution of Cash: Mechanics &
LimitationsMechanicsD S/HsMechanics► D transfers Business 2 to newly
formed C in exchangefor C stock, cash (debt funded), and C’s assumption
ofsome of D’s outstanding liabilities and D distributes thestock of C to its
shareholders.C stock, cash, &assumption of DliabilitiesDCBusiness
2LimitationsCLimitations► Basis Limitation: Assumed liabilities and distributed
cash are cumulatively limited to thebasis of the assets transferred by D to
C.► To the extent that the liabilities assumed by C and cash distributed to D
exceed the basis in thetransferred assets D will recognize gaintransferred
assets, D will recognize gain.► Contingent liabilities generally excluded.►
Use of Cash: Cash must be used by D (i) to repay its debt* OR ii) for
distribution to itsshareholders (i.e., dividends or redemptions).Eighth Annual
Domestic Tax Conference9shareholders (i.e., dividends or redemptions).
Controlled Securities & Stock ExchangePrior to No-Rule:
MechanicsMechanics► D issues $600M principal amount short-term debt (ST
debt) toD S/Hs$600M ► D issues $600M principal amount short term debt
(ST debt) toa financial institution (FI), which holds the debt for its ownaccount,
in exchange for cash.► D transfers Business 2 to a newly formed C in
exchange for► $300M of C securities (long term debt) andDFIST debt$600M
cash► $300M of C securities (long term debt), and► Two classes of C
common stock – Class A high vote(80% vote & 60% value) and Class B low
Beyond Asia - Strategies to
support the quest for growth
98 views
Beyond Asia - developed-
markets perspectives – meeting
the challenge of changi…
92 views
Rethinking profitable growth - the
productivity imperative for
foreign multinati…
393 views
The world is bumpy -
globalization and new strategies
for growth
97 views
When for profit & not for profit
worlds collide
172 views
Compliance with closing
agreements and other IRS
examination and compliance
init…
153 views
Tax-exempt organizations - how
the government can help you
129 views
The evolving value chain in life
sciences
620 views
Executive compensation:
changes you cannot afford to
ignore
257 views
Working with your financial
statement auditor: the effect of
PCAOB regulation of…
170 views
Road map to emerging markets:
spotting opportunities and
issues in health scienc…
162 views
State and local tax and
insurance tax update
247 views
The Medical Device Excise Tax:
ready or not?
411 views
Follow Author

vote (20% vote& 40% value).D t f th C iti (300M) d Cl B l tBus 2$300M C►
D transfers the C securities (300M), and Class B low voteshares to FI in
exchange for the $600M ST debt anddistributes the C Class A stock to D’s
shareholders in adistribution intended to qualify under Sections 355
and368(a)(1)(D).DD S/HsC stockFI$300M Csecurities & CClass B
shares$600M D Bus 2► FI sells the C securities & Class B shares for cash
in a publicoffering.CBus 2$600M DDebtBus 2Eighth Annual Domestic Tax
Conference10Bus 2
Controlled Securities & Stock Exchange Prior toNo-Rule: Mechanics
(continued)D S/Hs New S/Hs FID C80% Vote/60% Value20% Vote/40%
ValueSecurityH ld$ FeesD CBus 2$600M CashHolders► D now has $600M
of cash with no restrictions on what the cash can be used for.R i t f C t ll d St
k d C t ll d S iti i tl NOT b i li it d ( di t ib ti f h► Receipt of Controlled Stock
and Controlled Securities is currently NOT basis limited (compare distribution
of cash orassumption of a liability).► Key to tax free treatment of Securities
Exchange & Stock Exchange is that the Securities & Stock were used toretire
D “Debt”.Eighth Annual Domestic Tax Conference11
Revenue Procedure 2013-3, Section 5, No-Rule, Areas Under Study, y►
New Debt Issuance: Whether either sections 355 or 361 applies to a
distributingcorporations distribution of stock or securities of a controlled
corporation in exchangefor and in retirement of debt issued in anticipation of
the distributionfor, and in retirement of, debt issued in anticipation of the
distribution.► Control: Whether a corporation is a "controlled corporation"
within the meaning ofp p gsection 355(a)(1)(A) if, in anticipation of a
distribution, control was acquired as theresult of a recapitalization, or if, in
anticipation of a distribution such corporation issuesstock to another person
having different voting power per share than the stock held bythe distributing
corporation.g p► North-South: Whether transfers of property by a person to a
corporation and transfersf t b th t ti t th t i h t t ibl t tof property by that
corporation to that person in what are ostensibly two separatetransactions
(so-called "north-south" transactions), at least one of which is a
distributionwith respect to the corporations stock, a contribution to capital, or
an acquisition ofstock, are respected as separate transactions for Federal
income tax purposes.Eighth Annual Domestic Tax Conference12
North-South ExampleParent► For business reasons, D would like todistribute
the stock of C to ParentParentDCash ControlledStockdistribute the stock of C
to Parent.► However, Distributing is subject to certain debtcovenants and
Parent needs to contribute cashor other assets to D in order to compensate
forthe loss of C.C► Alternatively, in a recent but unrelatedtransaction, Parent
contributed business assetsto D.► Under the current no-rule position,
theService will not rule on this transaction.► Potential 20% exception► Note:
the North South no rule applies to Section► Note: the North-South no-rule
applies to Section355 distributions as well as to other movementsof property

outside of the Section 355 context.Eighth Annual Domestic Tax Conference13
Section 355 & REIT ElectionEighth Annual Domestic Tax Conference14
Spin-off and related “Propco” REIT conversionStep 1: The dropdown Step 2:
The spin-offShareholdersPropcosharesShareholdersParent
Parent(Opco)Propertyassets andentitiesPropcosharesPropco PropcoEighth
Summary illustration of Opco/Propco spin-off (cont.)( )Step 3: Post-spin-offp
pShareholdersO100% 100%PropcoOpco(former Parent)LeaseAgreement**
Alternatively, Opco could enter into a management agreement withPropco or
a subsidiary of Propco.Eighth Annual Domestic Tax Conference16
Partnership IPO StructuresEighth Annual Domestic Tax Conference17
Partnership IPO StructuresOverview► Publicly Traded Partnership (PTP) /
Master LimitedPartnership (MLP)Partnership (MLP)► Limited availability►
Limited investor base► Complex reporting► Up-C Structure► Up C
Structure► Possible application where:► PTP is not available or desirableI t
lid t ith S► Issuer cannot consolidate with Sponsor► Tax Receivable
AgreementEighth Annual Domestic Tax Conference18► Full-on Incorporation
/ Traditional IPO
Partnership IPO StructuresPTP/MLP vs. Up-C vs. TraditionalPTP/MLP Up-C
Traditional IPOPublicSponsor PublicSponsorHigh-
VoteShPublicSponsorPubCoSharesIPO CoPTP/MLP OpCoIPO
Co.NonqualifyingIncomeQualifyingIncomeQualifying
&NonqualifyingIncomeQualifying &NonqualifyingIncomeEighth Annual
Domestic Tax Conference19
Partnership IPO StructuresComparison of IPO StructuresPTP / MLP► Double
tax only onUP-C► Double tax on Public’sTraditional IPO► Double tax on
everythingynonqualifying (blocked)income► Asset basis step up onsales of
equity except forshare► Asset basis step up onsales of Sponsor equityy
gunless Sponsor canconsolidate► No asset basis step up onsales of
equitysales of equity, except forblocked assetssales of equityEighth Annual
Partnership IPO StructuresUp-C Structure Benefits and Considerations►
Benefits► Tax receivable agreements► Tax receivable agreements► Cash
benefit to Founders► PubCo agrees to pay the Founders a percentage
(commonly 85%) of thecash tax benefit it receives from a positive Section
743(b) adjustment (andcash tax benefit it receives from a positive Section
743(b) adjustment (andother attributes) in OpCo’s assets► Founders are still
subject to a single level of tax► Provides multiple currencies (OpCo interests
and PubCo stock) forp ( p )future acquisitions and/or executive compensation
arrangements► Considerations► Considerations► Anti-churning rules (if
PubCo is related to Founders)► Introduces greater complexity from several

perspectives (e.g.,governance operating capital markets accounting tax)Eighth
Annual Domestic Tax Conference21governance, operating, capital markets,
accounting, tax)
Checkable Arrangements (a.k.a. VirtualIncorporations)p )Eighth Annual
Virtual incorporations► USP operates division X (“Division X”).► USP also
owns 100% of the stock ofBeginning structure► USP also owns 100% of the
stock ofOldco.► USP wants to incorporate Division X for taxreasons, but, due
to non-tax reasons (e.g.,g gUSP, , ( g ,non-transferrable assets, transfer
taxes,regulatory, etc.), USP cannot transfer theassets of Division X to another
legal entity.§ ( )OldcoDivisionX► Reg. §301.7701-3(a) provides that
a“business entity” that is not classified as acorporation (i.e., an “eligible
entity”) canelect to its classification for US federal taxOldcoXelect to its
classification for US federal taxpurposes. Division X is not an “entity”
forpurposes of the check-the-box regulations.Eighth Annual Domestic Tax
Conference23
Virtual incorporations (cont’d)► In order to obtain the benefits
of“incorporating” Division X, theContract executionUSPprofits interest
inBranchfollowing steps are taken:1. USP and Oldco enter into a
contractualarrangement, under which Oldco willshare in the economics of
Division X.Oldco► See Reg. §301.7701-1(a)(2) (“A jointventure or other
contractual arrangementmay create a separate entity for federal taxpurposes
if the participants carry on atrade, business, financial operation, ort d di id th
fit th f ”)Check-the-box electionDivisionXventure and divide the profits
therefrom.”)2. Division X elects to be treated as acorporation for US federal
tax purposes.► Same result if Division X is aUSPOldcobranch.► See, e.g.,
PLR 201305006.► “Entity” status considerations – howi ifi t?DivisionXprofits
interest Eighth Annual Domestic Tax Conference24significant?
Gone and back in 120 seconds – TaxableDistributions and Upstream
Reorganizationsp gEighth Annual Domestic Tax Conference25
Gone and back in 120 seconds► Parent is a holding company.► Sub 1 has
two lines of business (X and)ParentY).► Sub 2 has one line of business (X
only).Sub 2Sub 1X & Y X► For valid non-tax business reasons,Parent wants
only Sub 2 to operatebusiness line X.X & Y XEighth Annual Domestic Tax
Conference26
Gone and back in 120 seconds (cont’d)► Step 1: At 11:57 p.m. on Day 1,
Sub 1converts to an SMLLC pursuant toParentSub 1converts to an SMLLC
pursuant toapplicable state elective conversionstatutes.Sub 2X & Y XEighth
Gone and back in 120 seconds (cont’d)Parent► Step 2: At 11:58 p.m. on
Day 1, Sub 1LLC transfers business line X directly toSub 2S1Sub 1 LLCLLC

transfers business line X directly toSub 2 in exchange for no
consideration.XX & YXEighth Annual Domestic Tax Conference28
Gone and back in 120 seconds (cont’d)Parent► Step 3: At 11:59 p.m. on
Day 1, Sub 1LLC converts back to a corporationSub 2S1LLC converts back
to a corporationpursuant to applicable state electiveconversion statutes.Sub 1
LLCXY XEighth Annual Domestic Tax Conference29
Gone and back in 120 seconds (cont’d)Parent► Section 311(b)
distribution?► Section 332 liquidation followed by Section11:56 p.m.Sub
2Sub 1q y351 transfer?► Sideways reorganization with boot?► Upstream
reorganization?► See, e.g., PLR 201201012; PLR 201127004.XX & Y►
See, e.g., PLR 201201012; PLR 201127004.► New “technology?”► PLR vs.
opinion letter.Parent11:59 p.m.► State tax consequences.► Impact of
minority shareholder ownership ofSub 2Sub 1XYEighth Annual Domestic Tax
Conference30► Impact of minority shareholder ownership ofSub 1?
Key Divestiture Tax Concepts andComplexitiespEighth Annual Domestic Tax
Conference31
Results of Global Corporate Divestment Study ShowSignificant Planned
Divestiture Activity► Survey of 567 corporate executives representing more
than 14 industriesacross Americas, Asia Pacific, Europe, the Middle East and
Africa)► Significant findings► 46% of respondents are in the process of a
divestiture or are planning to divestwithin the next 2 yearsy► Sectors most
likely to divest include power and utilities, and consumer products► 50% of
respondents indicated that the level of preparation required for a
successfuldivestiture has increased over the past 2-3 years► 27% of
respondents found that "Determining and implementing tax planning" to be►
27% of respondents found that "Determining and implementing tax planning"
to beone of the 3 top challenges of their most recent divestiture► The other
two are: (i) negotiating TSAs, and (ii) dealing with the complexity of closing►
One of 5 key leading practices of successful divestitures is separation
planning,y g p p p g,including tax planning► The other four are: (i) portfolio
management, (ii) consider ing the full range of potentialbuyers, (iii) articulating
compelling value/growth story for each buyer, and (iv) preparingrigorously for
the divestment processEighth Annual Domestic Tax Conference32
Tax Complexities Must be Addressed Up Front toSuccessfully Divest► Tax-
Free Spinoffs► Significant lead time for IRS, SEC and/or local country
approvals► Carve-out financial statements are usually needed and are
complex especially for► Carve out financial statements are usually needed
and are complex, especially forlarge businesses and/or those operating in
multiple countries► Primary identification of tax costs and complications to
creating SpinCo often mustbe quantified and considered before a public
announcement can be madeIRS li f i i i t l tt li h tl t t d ddi t ti l► IRS policy
for issuing private letter rulings has recently contracted, adding
potentialcomplexity and risk► Divestitures, in General► If financial

statements are needed, begin tax planning very early in process► Do not
underestimate the complexity of unwinding previously integration tax
operations and/orthe complexity of creating an efficient multinational
“Spinco”► Tax basis and valuation information needs to be sufficiently
detailed to allow for calculation ofdi t d i di t t t f ti “S i ” l l t tdirect and indirect
tax costs of creating “Spinco” legal structure► Consideration must be given
to trapped cash within “Spinco” structure and cash that maybecome trapped
as a result of sale of “Spinco” stock or assets► A multi-faceted divestiture
strategy that considers sale, joint-venture, spinoff, and/or IPO is verycomplex
but likely to produce the most successful outcomeEighth Annual Domestic
Tax Conference33complex but likely to produce the most successful outcome
Chairman Camp’s Small Business TaxReform Draft ProposalpEighth Annual
Camp Draft ProposalOverview► On March 12, 2013, House Ways and
Means Committee ChairmanDave Camp (R-MI) released a discussion draft
for reforming the taxDave Camp (R MI) released a discussion draft for
reforming the taxrules affecting small businesses.► The draft is intended to
solicit feedback from a broad range ofstakeholders practitioners economists
and members of the generalstakeholders, practitioners, economists, and
members of the generalpublic on how to improve on the proposal.► The
draft presents two options for the reform of pass-through entities► Option 1
– Retains Subchapter K and Subchapter S as separate.► Option 2 – Unified
rules for partnerships and S corporations.Eighth Annual Domestic Tax
Conference35
Camp Draft ProposalOption 1 – Revisions to Subchapters K and S►
Subchapter K revisions:► Repeal guaranteed payment rules► Repeal
guaranteed payment rules.► Require basis adjustments upon partnership
distributions of property or transfers ofinterests in a partnership.► Adjust the
limitation on a partner’s share of losses to take into account the
partner’sshare of the partnership’s charitable contributions and foreign
taxes.► Apply Section 751(b) to all inventory items, not just substantially
appreciatedinventory items.► Eliminate the current seven-year limitation on
the recognition of pre-contribution► Eliminate the current seven year
limitation on the recognition of pre contributiongains or losses on distributions
of property.Eighth Annual Domestic Tax Conference36
Camp Draft ProposalOption 1 – Revisions to Subchapters K and S►
Subchapter S revisions:► A permanent reduction in the recognition period for
the built-in gains tax under► A permanent reduction in the recognition period
for the built in gains tax underSection 1374 from 10 years to 5 years.
Correspondingly, the draft would makepermanent the rule that installment
sales are governed by the provision that wasapplicable when the sale
occurred.► Increase to 60 percent (from 25 percent) the amount of gross
receipts that an S► Increase to 60 percent (from 25 percent) the amount of

gross receipts that an Scorporation with Subchapter C earnings and profits
may have before being subjectto the tax on excess passive investment
income.► Permit nonresident aliens to be potential current beneficiaries of
electing smallbusiness trusts (ESBTs)business trusts (ESBTs).Eighth Annual
Camp Draft ProposalOption 2 – Unified Rules for Passthroughs► This option
repeals Subchapter K and Subchapter S and replacesthem with a uniform set
of rules that apply to non-publicly tradedthem with a uniform set of rules that
apply to non publicly tradedbusinesses for Federal tax purposes regardless of
how the businessis organized for state law purposes.► Would the rules
apply to any non-public entity?► Would publicly traded partnerships be
eligible for flow-through treatment?► Transition rules?► The new rules
would:► Allow contributions of property and money on a tax-free basis.►
Maintain the passthrough nature of an entity’s items (and preserve the
character ofthose items).► Permit special allocations of only net ordinary
income or loss net capital gain or► Permit special allocations of only net
ordinary income or loss, net capital gain orloss, and tax credits (and prohibit
special allocations of individual items within eachof those three
categories).Eighth Annual Domestic Tax Conference38
Camp Draft ProposalOption 2 – Unified Rules for Passthroughs► The new
rules would (continued):► Require basis adjustments upon a distribution of
property by the passthrough entity► Require basis adjustments upon a
distribution of property by the passthrough entityor a transfer of an interest in
a passthrough entity.► Require entity-level withholding on the passthrough
entity’s income and gain with acorresponding credit for the owner’s tax
reporting.► Limit deductions for losses to an owner’s basis in his passthrough
interest but► Limit deductions for losses to an owner s basis in his
passthrough interest, butallow excess losses to be carried forward
indefinitely.► Limit tax-free distributions (of money and property) to an
owner’s basis in hispassthrough interest.► Require passthrough entities to
recognize gain on all distributions of appreciatedproperty and require owners
to take a carryover basis in the distributed property (topreserve losses in
distributed property).► Allow owners to include entity-level debt (both
recourse and non-recourse) in theiry ( )basis in their passthrough interest.►
Allow owners to be treated as employees of the business.Eighth Annual
Questions and answersEighth Annual Domestic Tax Conference40
Thanks for participatingEighth Annual Domestic Tax Conference41
LEARN ABOUT US USING SLIDESHARE PRO & MORE DEVELOPERS & API
Search

Follow us on
LinkedIn
Follow us on
Twitter
Find us on
Facebook
Find us on
Google+
© 2013 SlideShare Inc. All rights reserved.
About
Careers
Our Blog
Press
Contact us
Help & Support
SlideShare 101
Terms of Use
Privacy Policy
Copyright & DMCA
Community Guidelines
SlideShare on mobile
Go PRO
Business Solutions
Developers Section
Developers Group
Engineering Blog
Blog Widgets
new

Recent developments in corporate and partnerships implications for transac

Recommended

Recommended

More Related Content

What's hot

What's hot (15)

Viewers also liked

Viewers also liked (14)

Similar to Recent developments in corporate and partnerships implications for transac

Similar to Recent developments in corporate and partnerships implications for transac (20)

Recent developments in corporate and partnerships implications for transac