The Pepper Minute: Corporate Inversions
Appel: Corporate Inversions Could Mean Big Tax Bills For Shareholders
What Questions CEOs and Board Members Should Be Asking Themselves About Tax Inversions
Private Equity's Inversion Excursion: Pepper Hamilton Talks Tax With the Deal
The M&A Word of the Day® from the Book of Jargon® – Global Mergers & Acquisitions Is Inversion
The bond yield curve inverted in October 2022. When that occurred, it started a countdown to recession. At least it has every time since 1968. Specifically, for the last eight recessions since 1968, every single recession was...more
Our Federal Tax Group finds the sweet spot for corporate inversions. If a U.S. corporation’s shareholders obtain between 50% and 60% of the stock, the exchange could be taxable....more
Generally speaking, a corporation inversion is a process of changing the holding structure of an existing company by transferring all of the existing company’s issued share capital from its shareholders to a new company, in...more
Here's a summary of the new tax provisions in the Build Back Better Act proposed by the Senate Finance Committee, as compared to the version that the House passed on November 19, 2021....more
Generally, an “inversion” is a transaction in which a non-U.S. corporation directly or indirectly acquires substantially all of the properties held by a U.S. corporation or partnership, after which the former owners of that...more
The American Jobs Plan is a proposal to increase investment in infrastructure, the production of clean energy, the care economy and other priorities. The Made in America Tax Plan (Tax Plan) is the vehicle to pay for the...more
In 2016, the Obama administration issued a series of rules and regulations designed to stem the flow of corporate inversions – transactions where U.S. corporations moved offshore to avoid the high 35% U.S. corporate tax rate....more
Jobs Report Friday again. Here’s what we’re watching, including the possibility of scary low numbers thanks to the only-recently-resolved GM strike....more
Many of the core provisions in the Tax Cuts and Jobs Act (TCJA) — including the corporate tax rate reduction and the fundamental reworking of the U.S. international tax regime — were geared toward addressing the uncompetitive...more
New regulations more notable for what they retain than what they change. Key Points: ..The US anti-inversion rules have more than a 15-year history of impacting the structure and practicality of certain cross-border...more
On July 11, 2018, the Treasury Department and the IRS published final Treasury regulations on inversion transactions (the “Final Regulations”). The Final Regulations substantially adopt the temporary Treasury regulations...more
INTRODUCTION - On July 11, 2018, Treasury and the Internal Revenue Service (IRS) published final inversion regulations (TD 9834) which are largely consistent with the temporary (T.D. 9761) and proposed regulations...more
On July 11, 2018, the U.S. Treasury Department and the Internal Revenue Service (the IRS) issued final regulations under Section 7874 and related sections of the Internal Revenue Code of 1986, as amended, (the Code)...more
Six months after the most significant U.S. tax reform legislation since 1986 was signed into law, it is still too early to predict the long-term effects. A number of technical uncertainties remain, and taxpayers are...more
As we hold our breaths at the opening bell to see if last week’s volatility continues, we consider the impact of computer-driven index funds on that market rollercoaster....more
On 26 October, Hogan Lovells hosted its inaugural Sovereign Investor Conference where investment professionals as well as deal and regulatory lawyers discussed the key issues facing government-sponsored investors. Topics they...more
On September 29, 2017, the United States District Court for the Western District of Texas granted summary judgment in favor of the U.S. Chamber of Commerce and Texas Association of Business, holding that the Internal Revenue...more
On September 29, 2017, the United States District Court for the Western District of Texas struck down a 2016 temporary regulation designed to limit corporate inversions(the “Rule”). Rule was simultaneously issued as a...more
In a case arising out of the inversion transaction where Medtronic merged with Coviden, the Minnesota Supreme Court spoke on the proper test of determining when an action is derivative or direct in In re Medtronic, Inc....more
A multinational corporate group headed by a U.S. parent corporation is often at a competitive disadvantage compared to a multinational corporate group headed by a foreign corporation. While a multinational corporate group...more
Blake Rutherford and Howard Schweitzer of Cozen O'Connor Public Strategies analyze the future of tax reform and the implications on the business community. Blake: Today for this special briefing on tax reform, which is...more
On March 8, 2017, Skadden hosted a webinar titled “Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions.” The Skadden panelists were tax partners Nathaniel Carden and Armando Gomez, and litigation...more
In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more
United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more
Mean Girls v. The Right of Publicity: Lessons Learned From the Lohan and Gravano Lawsuits - On September 1, 2016, a New York appellate court ended two closely watched right of publicity lawsuits brought by Lindsay...more