The U.S. Supreme Court today upheld the constitutionality of the so-called “mandatory repatriation tax” in a narrow ruling, stating that the MRT taxes realized income — income earned by the offshore corporation — and...more
Recently proposed IRS regulations materially change the way stock and assets of foreign corporations that are “controlled foreign corporations” (CFCs) can be used to support debt of U.S. affiliates. ...more
What is an inversion?
An inversion is a transaction that results in an existing U.S. company becoming a foreign company or becoming a subsidiary of a foreign parent. Historically, inversions involved U.S. companies...more
9/29/2014
/ AbbVie ,
Asset Stripping ,
Burger King ,
Controlled Foreign Corporations ,
Corporate Counsel ,
Corporate Taxes ,
EU ,
Medtronic ,
Mylan Pharmaceuticals ,
Offshore Funds ,
Pfizer ,
Popular ,
Repatriation ,
U.S. Treasury ,
Walgreens