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Corporate Taxes › Subsidiaries › Inversion

A&O Shearman

Treasury and IRS Issue Final Regulations on Inversions

A&O Shearman on

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

Kelley Drye & Warren LLP

Corporate Inversions

Kelley Drye & Warren LLP on

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

Bilzin Sumberg

Ruling Demonstrates Potential for Inversion Rules to Apply in Inbound Structures

Bilzin Sumberg on

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

Troutman Pepper

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

Troutman Pepper on

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

Bilzin Sumberg

Corporate Inversions Showing No Signs of Slowing Down

Bilzin Sumberg on

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

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