International Tax Advisory: New Temporary Regulations Continue the Fight Against Inversions

Alston & Bird

On April 4, the Treasury released temporary regulations to attack (and prevent) inversions. Aimed at transactions designed to avoid the purposes of Sections 7874 and 367 and certain post-inversion avoidance transactions, the regulations take particular aim at “serial inverters.” The regulations incorporate the provisions in Notices 2014-52 and 2015-79, with certain modifications (see our coverage of prior anti-inversion guidance here). In addition, the temporary regulations introduced rules to (1) identify the foreign acquiring corporation (FAC) in multistep acquisitions; (2) disregard FAC stock attributable to prior domestic entity acquisitions; (3) require a controlled foreign corporation (CFC) to recognize gain on certain transfers that shift assets to non-CFC foreign related persons; and (4) clarify the definition of “group income” for the substantial business activities test.

The temporary and proposed regulations are the latest in a string of anti-inversion activity by the Treasury and IRS. Commentators have already credited the new regulations with the undoing of a number of anticipated, high-profile transactions. The new rules could also limit the benefits of previously completed inversion deals. While the new regulations package has teeth, many people, including President Obama and Treasury Secretary Lew, continue to call for legislative action to address the inversion problem more comprehensively.


Added to the Code in 2004 to combat tax-motivated inversions, Section 7874 applies if (1) a FAC acquires substantially all the assets of a U.S. corporation or partnership; (2) the former owners of the U.S. entity hold at least 60 percent by vote or value of the stock of the FAC after the acquisition by reason of holding stock of or partnership interests in the U.S. entity (the “ownership test”); and (3) the FAC’s expanded affiliated group (EAG) does not have substantial business activities in the foreign country where the foreign acquiring corporation is incorporated. Section 7874 fully taxes “inversion gain” to the inverted entity (disallowing the use of offsetting tax attributes) or, in cases where the former owners of the U.S. entity hold at least 80 percent of the FAC, treat the FAC as a domestic corporation for tax purposes.

In 2014, the Treasury and IRS released Notice 2014-52, announcing rules that generally made it more likely that an inversion would be subject to Section 7874 (by disregarding certain stock of the FAC) and restricting the FAC’s ability to access earnings of CFCs of the inverted U.S. corporation. The Treasury and IRS followed up the 2014 notice with Notice 2015-79, which introduced provisions to (1) require the FAC to be a tax resident of the relevant foreign country to be considered having substantial business activities there; (2) disregard FAC stock in certain “third country” transactions for purposes of the ownership test; and (3) clarify the definition of “nonqualified property” for purposes of disregarding FAC stock (under the “anti-stuffing rules” of Notice 2014-52).

Among other things, Notice 2015-79 also sought to limit post-inversion tax benefits by expanding the definition of “inversion gain” to include income recognized by the inverted U.S. entity from certain indirect transfers or licenses of property. In addition, the 2015 notice required an exchanging U.S. shareholder to recognize, under Section 367, all gain realized on an exchange of CFC stock, regardless of the CFC’s undistributed earnings and profits, if the exchange terminated a foreign subsidiary’s CFC status or diluted a U.S. shareholder’s interest in the CFC.

New Provisions in the 2016 Temporary Regulations

One concern of the Treasury and IRS is that taxpayers are taking the position that certain transactions are not domestic entity acquisitions subject to Section 7874 even though the transactions involve the policy concerns underlying the statute. For example, a foreign corporation (ForCo1) may acquire substantially all the assets of a U.S. entity (the “initial acquisition”) that does not implicate Section 7874, e.g., because the ownership test is not met or the EAG has substantial business activities in the relevant foreign country. Then, pursuant to a plan or series of transactions that includes the initial acquisition, another foreign corporation (ForCo2) acquires substantially all of the assets of ForCo1 (the “subsequent acquisition”). Under Section 1.7874-2(c)(2), ForCo2 is not considered to have indirectly acquired the assets of the domestic entity.

To address the government’s concern, a new “multiple-step acquisition rule” treats the subsequent acquisition as a domestic entity acquisition, ForCo2 as a FAC, and stock of ForCo2 received in exchange for ForCo1 stock, pursuant to the subsequent acquisition, as stock held by reason of holding stock in the domestic entity. Moreover, if pursuant to the same plan or series of related transactions, a foreign corporation (ForCo3, etc.) acquires substantially all the properties held by a subsequent acquiring corporation (i.e., ForCo2), the principles of the multiple-step acquisition rule extend to such subsequent acquisitions. Section 7874 may apply to the initial and subsequent acquisitions.

The temporary regulations also provide that, for purposes of calculating the ownership percentage for a domestic entity acquisition (the “relevant domestic entity acquisition”), the denominator of the ownership fraction will exclude FAC stock attributable to certain prior domestic entity acquisitions. This “multiple domestic entity acquisition rule” applies if the FAC (or a predecessor) completed one or more domestic entity acquisitions within the 36-month period ending on the signing date for the relevant domestic entity acquisition. The regulations describe a three-step process to determine the amount of FAC stock excluded, which is based on the current value of the FAC shares issued in the prior acquisition, adjusted for intervening redemptions and other capital structure changes.

The multiple domestic entity acquisition rule applies after taking into account Section 1.7874-2(e), which may treat multiple acquisitions as a single acquisition. If two acquisitions are aggregated under Section 1.7874-2(e), they are not treated separately for purposes of the new multiple domestic entity acquisition rule. In general, prior domestic entity acquisitions will not implicate the multiple domestic entity acquisition rule if the ownership percentage for the acquisition was less than 5 percent and the value of the by-reason-of stock received by the former owners of the domestic entity did not exceed $50 million.

The preamble indicates that the Treasury and IRS worry that certain Section 351 transfers by an expatriated foreign subsidiary (i.e., CFCs of the inverted domestic entity) could dilute a U.S. shareholder’s indirect interest in the property without gain recognition by the CFC or by the U.S. shareholder. The temporary regulations will require the expatriated foreign subsidiary to recognize all gain in the transferred property that is not otherwise recognized. This “Section 367(b) asset dilution rule” applies when an expatriated foreign subsidiary transfers property (other than stock of a lower-tier expatriated foreign subsidiary) in a Section 351 exchange to a foreign transferee corporation during the applicable period. An exception applies to transfers in which there is only a de minimis shift of ownership of the transferred property to non-CFC foreign related persons.

Under Notice 2015-79 (and now the new regulations), an EAG cannot have substantial business activities in a foreign country unless the FAC is subject to tax as a resident in that country. Under regulations finalized in mid-2015, substantial business activities means 25 percent or more of each of an EAG’s employees, assets and income being in the relevant country. The temporary regulations clarify that financial reporting principles are relevant only in determining the amount of items of income taken into account, as the EAG must take into account all items recognized by all group members (based on the regulatory definition of EAG) during the testing period.

Treasury Makes Big Moves in Proposed Earnings Stripping Regulations

Dovetailing with the new anti-inversion regulations and released on the same day, proposed regulations under Section 385 tackle earnings stripping structures that increase related-party debt that does not finance U.S. investment. Section 385(a) authorizes the Treasury to prescribe regulations to determine whether an interest in a corporation is debt or equity (or part debt and part equity) for tax purposes. A substantial body of case law developed around debt-equity characterization in the absence of regulations (the last set were withdrawn in 1983). In a sharp departure from the facts-and-circumstances approach of the courts and Section 385(b), certain provisions in the new regulations would categorically treat related-party debt as stock if issued in certain transactions. The proposed rules also set forth documentation requirements for certain taxpayers to treat related-party interests as debt and allow the IRS on audit to treat related-party interests as part debt and part equity (rather than as all of one or the other).

The proposed regulations apply to purported debt issued by a corporation or controlled partnership to related parties, specifically members of an “expanded group” (EG). Interests not designated as debt and interests among members of the same U.S. consolidated group (treated as a single corporation under the rules) are generally not covered. Though defined by reference to the term “affiliated group” in Section 1504(a), EG is a broader concept. A corporation is part of an EG if group members own 80 percent of the corporation by vote or value (not both, as required under Section 1504). An EG may include foreign and tax-exempt corporations and corporations held indirectly through partnerships, and the attribution rules of Section 304(c)(3) apply. Notably, the regulations apply whether related parties are foreign or domestic.

Section 1.385-3 of the proposed regulations offers three rules for treating an EG interest (EGI) as stock: the general rule, the funding rule and the anti-abuse rule. These rules reflect the Treasury’s concern that debt issued in (or to fund) particular transactions has limited nontax significance and, therefore, produces improper results. The general rule treats an EGI as stock to the extent issued by a corporation to a member of the corporation’s EG in a distribution, in exchange for expanded group stock, other than a defined exempt exchange, or in exchange for property in an asset reorganization, to the extent a shareholder that was an EG member receives debt in exchange for stock of the transferor corporation. The funding rule treats as stock an EGI issued with the principal purpose of funding a transaction described in the general rule. Under the anti-abuse rule, a debt instrument is treated as stock if issued with the principal purpose of avoiding the purposes of the regulations. Significantly, these rules (and provisions related to consolidated groups) are generally effective for debt instruments issued or deemed issued on or after April 4, 2016. Under transition rules, however, certain distributions and acquisitions occurring before April 8, 2016, may not be taken into account, and certain debt instruments may continue to be treated as debt until after the regulations become final.

Under Section 1.385-2 of the proposed regulations, certain taxpayers must prepare and maintain timely documentation to treat an EGI as debt. Specifically, the documentation must evince a legally binding obligation to pay, the creditor’s right to enforce the obligation, a reasonable expectation of repayment at the time the interest is created and an ongoing debtor-creditor relationship consistent with arm’s-length relationships between unrelated parties. While these characteristics are derived from case law and Section 385(b), the regulations impose a “degree of discipline in the creation of necessary documentation, and in the conduct of reasonable financial diligence … that exceeds what is required under current law.” The Treasury cites the fact-intensive nature of debt-equity characterization and the increased complexity of related-party transactions as justification for the documentation rules, which apply only if an EG member’s stock is traded on an established financial market or if certain financial thresholds are met ($100 million in assets or $50 million in revenues). Of course, satisfying these requirements will not be dispositive of an EGI’s treatment for tax purposes. Rather, the documentation is meant to inform a larger facts-and-circumstances analysis. The documentation rules are not effective until the proposed regulations become final.

The Treasury believes that the all-or-nothing approach to debt-equity characterization often fails to reflect economic substance. Consequently, Section 1.385-1(d) of the proposed rules permits (but does not require) the IRS to bifurcate related-party interests and treat them as part debt and part stock. For purposes of this rule, a lower 50 percent threshold for relatedness applies. The Treasury makes clear that the proposed regulations do not affect the IRS’s authority to disregard an interest as stock or debt, treat a purported debt interest as debt or equity of another entity, or otherwise treat an instrument according to its substance. These provisions would not be effective until the regulations become final.

While Notices 2014-52 and 2015-79 hinted at earnings stripping regulations to combat post-inversion avoidance schemes, the proposed rules go well beyond that aim. The regulations ensnare common related-party financing structures outside the inversion context. There is also some question whether the rules exceed the Treasury’s authority under Section 385—particularly Section 1.385-3, which categorically treats certain related-party interests as stock, eschewing the factor-based analysis recommended by the statute. The Treasury has invited comments by July 7, 2016, on the proposed regulations, including whether the proposed rules merit additional guidance under Section 909 regarding hybrid splitter arrangements.

View Advisory as PDF

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Alston & Bird | Attorney Advertising

Written by:

Alston & Bird

Alston & Bird on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.