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Corporate Taxes › Internal Revenue Service › Pfizer

A&O Shearman

Texas Federal District Court Invalidates IRS Regulations Limiting Inversion Transactions

A&O Shearman on

On September 29, 2017, the United States District Court for the Western District of Texas granted summary judgment in favor of the U.S. Chamber of Commerce and Texas Association of Business, holding that the Internal Revenue...more

Baker Donelson

New "Inversion" Proposed Regulations Inspired By The Pfizer/Allergan Deal May Impact Corporate Tax Planning Strategies

Baker Donelson on

The Treasury Department has recently promulgated proposed regulations dealing with so-called inversion transactions. Inversion transactions are ones in which a U.S. corporation changes its domicile to a nation with a more...more

BakerHostetler

Proposed Regulations Would Fundamentally Change Treatment of Intra-Group Debt Transactions

BakerHostetler on

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

Lowndes

New Temporary Inversion Regulations

Lowndes on

The IRS once again is targeting inversions, and this time there have been immediate tangible results. The IRS issued temporary regulations on Monday targeting inversion transactions. An inversion occurs where a foreign...more

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