On October 13, 2016, the IRS and Treasury Department issued much anticipated regulations (the “Final” or “Temporary” Regulations) under Internal Revenue Code section 385. These regulations, which consist of both temporary...more
11/10/2016
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Debt ,
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Expanded Group Instruments (EGIs) ,
Financial Institutions ,
Foreign Issuers ,
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Stocks ,
U.S. Treasury
On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more