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Inversion Internal Revenue Service

Lowndes

Treasury Strips Away Obama Administration Earnings Stripping Rules

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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

Latham & Watkins LLP

Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform

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New regulations more notable for what they retain than what they change. Key Points: ..The US anti-inversion rules have more than a 15-year history of impacting the structure and practicality of certain cross-border...more

A&O Shearman

Treasury and IRS Issue Final Regulations on Inversions

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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

A&O Shearman

Texas Federal District Court Invalidates IRS Regulations Limiting Inversion Transactions

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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

Skadden, Arps, Slate, Meagher & Flom LLP

"Key Takeaways: Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions"

On March 8, 2017, Skadden hosted a webinar titled “Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions.” The Skadden panelists were tax partners Nathaniel Carden and Armando Gomez, and litigation...more

Orrick, Herrington & Sutcliffe LLP

IRS Reverses its Position Regarding the Treatment of Merger Breakup Fees

In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more

Fenwick & West LLP

Intellectual Property Bulletin - Fall 2016

Fenwick & West LLP on

Mean Girls v. The Right of Publicity: Lessons Learned From the Lohan and Gravano Lawsuits - On September 1, 2016, a New York appellate court ended two closely watched right of publicity lawsuits brought by Lindsay...more

Seyfarth Shaw LLP

One Step Back, One Step Forward: New Debt-Equity Regulations Narrow Their Focus on Earnings Stripping

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Seyfarth Synopsis: On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final Regulations”). Drafted to curtail tax benefits accrued by...more

Cadwalader, Wickersham & Taft LLP

Controversial Debt-Equity Regulations Finalized With Limited Fixes, Concessions and Reservations by Government

On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more

Dechert LLP

Global Private Equity Newsletter - Summer 2016 Edition: New Proposed Regulations Increase Scrutiny on Related-Party Debt

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New rules recently proposed by the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) would re-characterize purported debt instruments as equity instruments, and could have significant implications...more

Dechert LLP

New Proposed Regulations Increase Scrutiny on Related-Party Debt

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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

Latham & Watkins LLP

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

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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

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

Morrison & Foerster LLP

Latest Treasury Action on Inversions Upends Pending Transactions and Surprises Many for Its Broad Scope and Use of Questionable...

On April 4, 2016, the Treasury Department and the Internal Revenue Service issued a sweeping package of new regulations intended to curtail inversion transactions (the “Regulations”). Many features of the Regulations had...more

Alston & Bird

International Tax Advisory: New Temporary Regulations Continue the Fight Against Inversions

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On April 4, the Treasury released temporary regulations to attack (and prevent) inversions. Aimed at transactions designed to avoid the purposes of Sections 7874 and 367 and certain post-inversion avoidance transactions, the...more

Morrison & Foerster LLP

Proposed IRS Debt-Equity Regulations: Aimed at PostInversion “Earnings Stripping,” But May Also Impact Ordinary Related-Party Debt

On April 4th, the Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 385 which could dramatically change how related-party indebtedness is treated for federal income tax...more

Cooley LLP

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

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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

King & Spalding

New Guidance Rewrites Debt/Equity Rules and Further Limits Inversions

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The IRS and Treasury Department released a package of temporary and proposed regulations on April 4, 2016 ostensibly aimed at further curbing corporate “inversion” transactions. The regulations cover a wide range of tax...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

Kilpatrick Townsend & Stockton LLP

Expanded Earnings Stripping Proposed Rules Will Impact Typical Debt Push Downs

In a surprising move amidst its continuing crack down on corporate inversions, the U.S. Treasury just proposed new regulations reflecting a broadly expanded approach to the practice of earnings stripping. Because an inversion...more

Lowndes

New Temporary Inversion Regulations

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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

Alston & Bird

International Tax Advisory: New IRS Notice Continues Attack on Inversions

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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

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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

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