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
3/3/2017
/ AbbVie ,
Capital Losses ,
Inversion ,
IRS ,
Offshore Companies ,
Pharmaceutical Industry ,
Shareholder Votes ,
Stocks ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Termination Payments
On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more
2/2/2017
/ Consumer Financial Products ,
Derivatives ,
Dividend-Equivalent Transactions ,
Exchange-Traded Products ,
Financial Institutions ,
Financial Markets ,
Internal Revenue Code (IRC) ,
IRS ,
Master Limited Partnerships ,
Partnerships ,
Qualified Derivatives Dealers (QDDs) ,
Section 871(m) ,
Securities ,
SIFMA ,
Stocks
On October 13, 2016, the IRS and Treasury Department issued much anticipated regulations (the “Final” or “Temporary” Regulations) under Internal Revenue Code section 385. These regulations, which consist of both temporary...more
11/10/2016
/ Bifurcation ,
Debt ,
Debt Instruments ,
Expanded Group Instruments (EGIs) ,
Financial Institutions ,
Foreign Issuers ,
IRS ,
Multinationals ,
Section 385 ,
Stocks ,
U.S. Treasury
On December 5, 2013, the Internal Revenue Service ("IRS") issued final regulations (the "Final Regulations") and proposed regulations (the "2013 Proposed Regulations") under section 871(m), which address withholding on...more