Consider this. While Pfizer boasts around $25 billion in cash, it's been estimated that more than three quarters of that cash is overseas because by registering its intellectual property in lower tax jurisdictions, it avoids the 35% U.S. tax rate. That's why it's effective tax rate last year was only 21%. But that money can't be used in the U.S. without taking a 35% haircut on repatriation. Pfizer has even stopped buying back stock in the first quarter of 2008 and borrowed because of a domestic cash shortfall. The conclusion is that with Lipitor going off patent in 2010 and with Viagra to soon follow, Pfizer needs its cash to pay its dividend which now exceeds 7% as the stock price makes new lows. The serendipitous conclusion that benefits all, would be a so called stock for stock tax free B reorganization under Section 368(a)(1)(B) of the Internal Revenue Code. Pfizer gets Dendreon at whatever price is agreed upon and Dendreon shareholders get Pfizer stock with a juicy dividend above 7% in a tax free transaction which Pfizer can do and still keep the cash it needs. Why statues of Ming are not even now being erected outside Pfizer Headquarters remains a mystery.
Jun 30, 2008
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