News & Analysis as of

Inversion Foreign Corporations

Whitcomb Selinsky, PC

What Is A Tax Inversion & Can It Save Your Company Money?

Whitcomb Selinsky, PC on

Apple, Inc. made headlines this year when it managed to avoid over $70 million in taxes that the U.S. said the company owed to the federal government. Estimates vary as to the amount of money Apple keeps offshore, but the...more

Dorsey & Whitney LLP

President Biden’s Made in America Tax Plan Would Treat More Cross-border Transactions as Inversion Transactions

Dorsey & Whitney LLP on

Generally, an “inversion” is a transaction in which a non-U.S. corporation directly or indirectly acquires substantially all of the properties held by a U.S. corporation or partnership, after which the former owners of that...more

Holland & Knight LLP

Biden Administration's Made in America Tax Plan: Interaction with OECD Inclusive Framework

Holland & Knight LLP on

The American Jobs Plan is a proposal to increase investment in infrastructure, the production of clean energy, the care economy and other priorities. The Made in America Tax Plan (Tax Plan) is the vehicle to pay for the...more

Lowndes

Treasury Strips Away Obama Administration Earnings Stripping Rules

Lowndes on

In 2016, the Obama administration issued a series of rules and regulations designed to stem the flow of corporate inversions – transactions where U.S. corporations moved offshore to avoid the high 35% U.S. corporate tax rate....more

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

Eversheds Sutherland (US) LLP

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

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

Wilson Sonsini Goodrich & Rosati

IRS Releases Final Regulations Addressing Corporate Inversions and Related Transactions

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

King & Spalding

Anti-Inversion Regulations Held to Violate Administrative Procedure Act

King & Spalding on

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

Kelley Drye & Warren LLP

Corporate Inversions

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

Latham & Watkins LLP

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

Latham & Watkins LLP on

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

Cooley LLP

Alert: Treasury Department Expands Anti-Inversion Rules, Earnings Stripping Rules

Cooley LLP on

On April 4, 2016, the United States Department of the Treasury issued temporary regulations that expand the scope of transactions subject to the rules designed to eliminate the US tax benefits of "inversions." The temporary...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

Cadwalader, Wickersham & Taft LLP

M&A Update: Broad Anti-Inversion Rules Released

On April 4, 2016, Treasury released new rules making it more difficult for some U.S. companies to invert (“Serial Inversion Regulations”), Proposed Regulations limiting the effectiveness of “earnings stripping” techniques...more

Alston & Bird

International Tax Advisory: New IRS Notice Continues Attack on Inversions

Alston & Bird on

There is no love lost between the U.S. Treasury and U.S. companies seeking offshore tax homes. Absent congressional action to stem the inversion tide, the Treasury and IRS are left to flex their regulatory and administrative...more

Proskauer - Tax Talks

IRS and Treasury Issue More Guidance on “Inversion” Transactions

Proskauer - Tax Talks on

The Treasury Department and the Internal Revenue Service have issued additional guidance about so-called “inversion” transactions. Generally, an inversion transaction results where a U.S. corporation (“U.S. Target”) is...more

Goulston & Storrs PC

IRS Issues More Anti-Inversion Rules

Goulston & Storrs PC on

Following on its prior Notice 2014-52 anti-inversion guidance, the IRS has issued new Notice 2015-79 to further limit (i) inversion transactions that are contrary to the purposes of the Section 7874 anti-inversion rules and...more

Latham & Watkins LLP

New Final Inversion Rules Maintain Tight Standard for Corporate Expatriations

Latham & Watkins LLP on

For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules. On June 3, 2015, the US Department of the...more

Lowndes

More Tough Talk on Cracking Down on Offshore Activity

Lowndes on

In what is becoming a popular refrain, we are continuing to hear tough talk by government officials on cracking down on offshore activity. The most recent target is once again corporate inversions. ...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

Cooley LLP

Alert: IRS and Department of the Treasury Notice Limits Inversion Transactions

Cooley LLP on

On September 22, 2014, the United States Department of the Treasury and the Internal Revenue Service issued a Notice (Notice 2014-52) that limit "inversion" transactions and their potential tax benefits. In general, an...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

Editorial: Corporate Inversions 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

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

Brownstein Hyatt Farber Schreck

Is Your Company Prepared For The Potential Impacts Of The Stop Corporate Inversions Act of 2014

As Congress Seeks Additional Funding, Inversion Proposal Emerges - Throughout the past several weeks, Pfizer’s attempt to acquire AstraZeneca has garnered significant congressional and media attention. Pfizer, a U.S....more

Cadwalader, Wickersham & Taft LLP

M&A Update: Senator Levin Introduces Anti-Inversion Act

On May 20, 2014, Sen. Carl Levin (D-MI) introduced the Stop Corporate Inversions Act of 2014 (the “Levin Bill”), which proposes significantly more stringent limits on the ability of U.S. companies to relocate outside the U.S....more

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