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Debt Inversion

Dechert LLP

New Proposed Regulations Increase Scrutiny on Related-Party Debt

Dechert LLP on

The U.S. Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently issued proposed regulations (the “New Proposed Regulations”) governing the federal income tax treatment of debt between certain related...more

Bilzin Sumberg

Proposed IRS and Treasury Regulations Have Broad Implications for Intercompany Debt Structures

Bilzin Sumberg on

On April 4, 2016, the U.S. Treasury Department and the Internal Revenue Service (“IRS”) issued proposed regulations ostensibly aimed at curbing inversions and earnings stripping, by companies located in the U.S. with overseas...more

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