Tax Lawyer, Vol. 54, No. 3 FOREIGN MERGERS UNDER SECTION 368(a)(1)(A) 555 555 A TRANSCONTINENTAL “A” TRAIN? FOREIGN MERGERS UNDER SECTION 368(A)(1)(A) Steven A. Bank* I. INTRODUCTION Globally, mergers and acquisitions reached a peak in 2000, with a record $3.5 trillion worth of transactions announced.1 This record number was fueled in part by an increase in the number of mergers involving corporations located outside the United States.2 Nearly half of the top twenty deals announced during 2000...