推 heacoun:財經專業就推CCLu囉.. 02/13 15:03
※ 引述《LedZeppelin (Ten Years Gone)》之銘言：
: 據說已經被Time Warner賣了，買下他的是Liberty Media
在newsweek找到這篇文章
裡頭還牽涉到什麼稅金問題
有財經專業的板友幫忙解釋一下吧
http://www.msnbc.msn.com/id/13006793/site/newsweek/
A Double Play for the Atlanta Braves
By Allan Sloan
June 5, 2006 issue - When baseball teams trade players, they often talk about
how the transaction is a "win-win" for both teams—which rarely proves to be
the case. But here's a potential swap that really would be good—financially,
at least—for both sides. That's Time Warner's proposed trade of the Atlanta
Braves to Liberty Media, a holding company renowned for its dealmaking. The
companies would bring home total tax savings I estimate at $700 million—far
more than the Braves are worth. Sure, we other taxpayers would be shut out.
But what's baseball without a sacrifice?
Most fans would call this long-pending transaction (which may finally have
been announced by the time you read this) a "sale" of the Braves. But it
would actually be a trade. To be specific, it's what tax techies call a
"cash-rich split-off, " a game that's just gotten a big assist from President
George W. Bush's recently enacted $70 billion tax cut.
How does the Tax Increase Prevention and Reconciliation Act of 2005 involve
the Braves? Here's the play-by-play. Time Warner would put the team (valued
at about $450 million) and about $1.35 billion of cash into a subsidiary. It
would then trade that subsidiary for a Liberty unit that would be holding
about $1.8 billion of the Time Warner stock that Liberty already owns. By the
time the fat lady sings, Liberty would own the Braves and a slug of cash, and
Time Warner would have gotten about 100 million of Liberty's 171 million Time
Warner shares.
That sure looks like a sale—but not to tax lawyers, because the tax-cut
legislation specifically blesses cash-rich split-offs. What's more, until
next May 17—a year after the tax-cut legislation took effect—a company can
include up to $3 of cash for every dollar worth of businesses that it trades
to another company in return for its own stock. (You need a business in the
deal to keep it safe from the IRS.) After that, the ratio drops to 2-to-1.
This one-year window provides an incentive for Liberty to do a cash-rich
split-off or two with News Corp. (in which it holds a 16 percent stake) by
next May.
By the way, I can't find any indication that Time Warner or Liberty got
designated Washington hitters to stick that 3-to-1 provision into the tax
bill. They seem to be taking advantage of the situation rather than having
created it.
--
“You can't hit what you can't see.”
By Walter Johnson
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