News & Analysis as of

Inversion

Blindauer Law PLLC - Government Contracts...

Government Contracts Issues for a Recession

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

Alston & Bird

The Inversion Sweet Spot

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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

Barnea Jaffa Lande & Co.

Corporate Inversion – Turning an Israeli Company into a Foreign Company

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

Cadwalader, Wickersham & Taft LLP

Build Back Better Act: Comparison of Senate Finance Committee and House Tax Provisions

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

Dorsey & Whitney LLP

President Biden’s Made in America Tax Plan Would Treat More Cross-border Transactions as Inversion Transactions

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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

Holland & Knight LLP

Biden Administration's Made in America Tax Plan: Interaction with OECD Inclusive Framework

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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

Lowndes

Treasury Strips Away Obama Administration Earnings Stripping Rules

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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

Robins Kaplan LLP

Financial Daily Dose 11.01.2019 | Top Story: Watching for the GM-strike Impact on the October Jobs Report

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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

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: US Tax Reform and Cross-Border M&A: Considering the Impact, One Year In

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

Latham & Watkins LLP

Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform

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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

A&O Shearman

Treasury and IRS Issue Final Regulations on Inversions

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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

Eversheds Sutherland (US) LLP

No rest for the weary - final regulations continue to target inversions without major changes

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

Wilson Sonsini Goodrich & Rosati

IRS Releases Final Regulations Addressing Corporate Inversions and Related Transactions

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

Skadden, Arps, Slate, Meagher & Flom LLP

US Tax Reform Update: Early Impact and Trends

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

Robins Kaplan LLP

Your Daily Dose of Financial News

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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

Hogan Lovells

Top Five Takeaways from Hogan Lovells Sovereign Investment Conference and a Tax List

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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

A&O Shearman

Texas Federal District Court Invalidates IRS Regulations Limiting Inversion Transactions

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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

King & Spalding

Anti-Inversion Regulations Held to Violate Administrative Procedure Act

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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

Stinson - Corporate & Securities Law Blog

Minnesota Supreme Court Rejects Delaware Test for Direct Versus Derivative Action

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

Kelley Drye & Warren LLP

Corporate Inversions

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

Cozen O'Connor

Beltway Briefing: Special Tax Policy Briefing

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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

Skadden, Arps, Slate, Meagher & Flom LLP

"Key Takeaways: Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions"

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

Orrick, Herrington & Sutcliffe LLP

IRS Reverses its Position Regarding the Treatment of Merger Breakup Fees

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

Skadden, Arps, Slate, Meagher & Flom LLP

"Business Tax Reform All but Certain in US, Europe"

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

Fenwick & West LLP

Intellectual Property Bulletin - Fall 2016

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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

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