Inverted Domestic Corporations

News & Analysis as of

M&A Update: Treasury Announces Second Anti-Inversion Notice

On November 19, 2015, Treasury issued Notice 2015-79 (the “Notice”), which announces Treasury’s intent to issue regulations reducing the tax benefits available to inverted groups and making it more difficult for some U.S....more

Tax Policy Update

As in the 9 percent "amusement tax" that the city of Chicago recently extended to online streaming services like Netflix and Amazon Prime, triggering a series of lawsuits alleging that the newly expanded tax was illegally...more

Congress Continues to Threaten Contracting by Inverted Domestic Corporations - Congressional Action May Further Restrict IDCs from...

Recent congressional action regarding Inverted Domestic Corporations (IDC) may lead to further limitations on the ability of IDCs to contract with the federal government. Starting with the 2002 legislation that established...more

Weekly Update Newsletter - December 2014 #3

GOVERNMENT CONTRACTS - DoD, GSA, and NASA Issue Proposed Rule to Amend FAR Prohibition on Contracting With Inverted Domestic Corporations – Representations and Notifications - ...more

Assessing Retroactive Inversion Legislation And Its Risks

The increasing use of corporate inversions, whereby a company via merger achieves 20 percent or more new ownership, claims non-U.S. residence, and is then permitted to adopt that country’s lower corporate tax structure and...more

The Real Tax Benefits of Inverting to Canada

On August 26, Burger King announced that it entered into an agreement to acquire Tim Hortons, Inc., the Canadian coffee-and-doughnut chain, in a transaction that will be structured as an “inversion” (i.e., Burger King will...more

Prohibition on Contract Awards to Companies That Were Formerly Based in the United States

On January 29, 2013, a final rule was issued prohibiting the award of contracts to inverted domestic corporations. The final rule requires an offeror to represent that it is not an inverted domestic corporation and creates...more

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