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The Barnes Group, Inc. is a Bristol, Conn. Transnational corporation that manufactures industrial and aerospace components. It operated several U.S. and foreign subsidiary corporations with which entered it into an agreement and plan for reinvestment and sought to reallocate assets from Asia to the U.S. without tax consequences. The article discusses the tax ramifications of the attempt, the company’s plan structure, , the step transaction doctrine, and the need to plan and execute with a business purpose.