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
New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions.
On April 4, 2016, the US Department of the Treasury (Treasury) and...more
4/21/2016
/ Acquisitions ,
Anti-Inversion Regulations ,
Controlled Foreign Corporations ,
Controlled Groups ,
Corporate Taxes ,
De Minimus Quantity Exemption ,
Dividends ,
Foreign Corporations ,
Inversion ,
IRS ,
Multinationals ,
Proposed Regulation ,
Related Parties ,
Stocks ,
U.S. Treasury
For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules.
On June 3, 2015, the US Department of the...more
6/11/2015
/ Bright-Line Rule ,
Corporate Taxes ,
Expatriates ,
Foreign Corporations ,
Foreign Ownership ,
GAAP ,
IFRS ,
Inversion ,
IRS ,
Multinationals ,
Pending Legislation ,
Safe Harbors ,
U.S. Treasury
New guidance seeks to curb the incidence of inversions and reduce the associated tax benefits, but also extends beyond inversions.
On September 22, 2014, the US Department of the Treasury (Treasury) and the Internal...more