Robert Rudnick

Robert Rudnick

Shearman & Sterling LLP

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Treasury and IRS Issue Inversion Notice

The Treasury Department and the IRS released Notice 2014-52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of...more

9/25/2014 - Corporate Taxes International Tax Issues Inversion IRS Tax Evasion U.S. Treasury

New Proposed Regulations Under Section 871(m) Adopt a Single Factor Test but Delay Effective Date Until 2016

On December 4, 2013, the Treasury Department and the Internal Revenue Service (the “IRS”) released new final and proposed regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more

12/9/2013 - Delays Financial Regulatory Reform Income Taxes IRS Swaps U.S. Treasury

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