On Oct. 13, 2016, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final and temporary regulations under Section 385 governing the treatment of certain instruments as debt or equity...more
On April 4, 2016, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued two sets of regulations, temporary regulations addressing “inversion” transactions and proposed regulations regarding the...more
What is an inversion?
An inversion is a transaction that results in an existing U.S. company becoming a foreign company or becoming a subsidiary of a foreign parent. Historically, inversions involved U.S. companies...more
9/29/2014
/ AbbVie ,
Asset Stripping ,
Burger King ,
Controlled Foreign Corporations ,
Corporate Counsel ,
Corporate Taxes ,
EU ,
Medtronic ,
Mylan Pharmaceuticals ,
Offshore Funds ,
Pfizer ,
Popular ,
Repatriation ,
U.S. Treasury ,
Walgreens