Corporate Taxes, Internal Revenue Code (IRC), Inversion

Treasury and IRS Issue Final Regulations on Inversions

A&O Shearman on 7/24/2018

On July 11, 2018, the Treasury Department and the IRS published final Treasury regulations on inversion transactions (the “Final Regulations”). The Final Regulations substantially adopt the temporary Treasury regulations...more

No rest for the weary - final regulations continue to target inversions without major changes

Eversheds Sutherland (US) LLP on 7/19/2018

INTRODUCTION - On July 11, 2018, Treasury and the Internal Revenue Service (IRS) published final inversion regulations (TD 9834) which are largely consistent with the temporary (T.D. 9761) and proposed regulations...more

IRS Releases Final Regulations Addressing Corporate Inversions and Related Transactions

Wilson Sonsini Goodrich & Rosati on 7/18/2018

On July 11, 2018, the U.S. Treasury Department and the Internal Revenue Service (the IRS) issued final regulations under Section 7874 and related sections of the Internal Revenue Code of 1986, as amended, (the Code)...more

Anti-Inversion Regulations Held to Violate Administrative Procedure Act

King & Spalding on 10/10/2017

On September 29, 2017, the United States District Court for the Western District of Texas struck down a 2016 temporary regulation designed to limit corporate inversions(the “Rule”). Rule was simultaneously issued as a...more

"Key Takeaways: Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions"

Skadden, Arps, Slate, Meagher & Flom LLP on 3/22/2017

On March 8, 2017, Skadden hosted a webinar titled “Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions.” The Skadden panelists were tax partners Nathaniel Carden and Armando Gomez, and litigation...more

Assessing Retroactive Inversion Legislation And Its Risks

Orrick, Herrington & Sutcliffe LLP on 9/11/2014

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

If I Had a Hammer – A Creative Method for Repatriating Offshore Corporate Profits

Gerald Nowotny - Law Office of Gerald R.... on 8/25/2014

In this era of corporate inversions, there seems to be a lot of mud-slinging going around. Congress and the current Presidential administration would like to label large multi-national corporations as traitors. Somewhere...more

Corporate Taxes › Internal Revenue Code (IRC) › Inversion