SPACs: the confluence of A-list celebs and Sec. 7874

Cross-border Tax Talks

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Thomas Groenen (PwC's US ITS-Financial Services Leader) discuss the renewed interest in special purpose acquisition companies (SPACs). Doug and Thomas cover: how Thomas made his way from the UK to the US; Thomas's advice for individuals interested in moving to the United States to become tax professionals; what a SPAC is and how it generally functions; the history of SPACs—dating back to the British 'South Sea bubble' in the early 18th century; how SPACs compare to and interrelate with IPOs; how and why individuals and entities invest in SPACs; the tax implications for SPAC investors; considerations regarding the SPAC's jurisdiction; the SPAC lifecycle, from founding to de-SPACing; the importance of choosing the correct investment vehicle (both corporate v. pass-through and domestic v. foreign); how the passive foreign investment company (PFIC) regime interplays with foreign SPACs; and the possible future of SPACs.­