Corporate Taxes, Subsidiaries, Foreign Corporations

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

Main Effects of U.S. Tax Reform on Foreign Taxpayers

Holland & Knight LLP on 1/3/2018

President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

Corporate Tax Residence: Another Chapter

Katten Muchin Rosenman LLP on 9/11/2017

Another Case on Corporate Tax Residence: Why Does It Matter? - Corporate tax residence is an area of enduring enquiry and focus for HM Revenue & Customs (HMRC) in the UK. Development Securities (No.9) vs. HMRC [2017]...more

Corporate Inversions

Kelley Drye & Warren LLP on 7/19/2017

A multinational corporate group headed by a U.S. parent corporation is often at a competitive disadvantage compared to a multinational corporate group headed by a foreign corporation. While a multinational corporate group...more

"IRS and Treasury Issue Final Debt/Equity Regulations"

Skadden, Arps, Slate, Meagher & Flom LLP on 10/26/2016

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

Ruling Demonstrates Potential for Inversion Rules to Apply in Inbound Structures

Bilzin Sumberg on 1/22/2015

In Private Letter Ruling 201432002 (the “PLR”), the IRS ruled that a foreign-to-foreign “F” reorganization did not implicate the Section 7874 anti-inversion rules. As a result, a foreign corporation (that was 100 percent...more

Anti-Inversion Legislation May Impact Non-Inverted Private Equity Deals

Troutman Pepper on 7/25/2014

Corporate inversions have been the target of regulatory or statutory tax proposals for many years. However, the recently attempted combination of Pfizer and AstraZeneca received prompt and more far-reaching attention in the...more

Corporate Inversions Showing No Signs of Slowing Down

Bilzin Sumberg on 6/19/2014

In a corporate inversion, a U.S. corporation (typically the parent of an affiliated group) becomes a wholly owned subsidiary of a foreign corporation (through a merger into the foreign corporation’s U.S. subsidiary) or...more

Corporate Taxes › Subsidiaries › Foreign Corporations

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