In the summer of 2021, K+S AG Kassel announced the sale of its American subsidiaries Morton Salt (USA), Windsor Salt (Canada) and SPL (Chile) to Stone Canyon Industries Holdings (USA) for a total of USD 3.2 billion.
This transaction, led by PwC Berlin tax partners Volker Booten and Holger Dallwitz, was supported by several PwC advisory and assurance specialists. PwC colleagues from countries across the globe including the Bahamas, Belgium, Brazil, Canada, Chile, China, Denmark, Malta, the Netherlands, and Peru, were also involved. Sullivan & Cromwell (USA) and Carey Abogados (Chile) provided legal representation.
K & S held Morton Salt (USA) through several subsidiaries, including a Dutch holding company and a Belgian finance company. As such, this necessitated substantial internal restructuring prior to the sale to ensure an efficient transfer for the buyer while minimizing U.S. tax risks.
Brix + Partners LLC, led by Gerald Brix (Partner) and Dana Atchley (Tax Attorney), provided tax advice for this restructuring and the subsequent sale. Brix + Partners LLC specializes in providing tax advice to DACHLI companies with holdings in the United States.