Derek Kershaw

Derek Kershaw

Shearman & Sterling LLP

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New Temporary Regulations Introduce a Welcome De Minimis Rollover-Shareholder Exception to US Anti Inversion Rules

On January 16, 2014, the Treasury Department and the Internal Revenue Service released new temporary regulations on one aspect of corporate inversions under Section 7874 (the “Regulations”) that altered and clarified the...more

1/22/2014 - Corporate Taxes De Minimis Claims De Minimus Quantity Exemption Exclusions Inversion IRS Shareholders U.S. Treasury

Focus on Tax Controversy & Litigation - July 2013

In this issue: - District Court Protects Opinion Work Product Contained in Tax Accrual Workpapers in Wells Fargo - IRS Restricts Private Letter Rulings for Spin-Offs and Other Corporate Nonrecognition...more

7/10/2013 - Business Privilege Corporate Taxes Income Taxes IRS Private Letter Rulings Tax Accrual Workpapers Tax Shelters Wells Fargo Work Product Privilege

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