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 merger), issued proposed regulations which are designed to attack corporate "earnings stripping" practices.

While the inversion portion of the package will have a limited application, the proposed earnings stripping regulations will have implications for any large company issuing "internal" debt for several reasons...