The Pepper Minute: Corporate Inversions
Appel: Corporate Inversions Could Mean Big Tax Bills For Shareholders
What Questions CEOs and Board Members Should Be Asking Themselves About Tax Inversions
Private Equity's Inversion Excursion: Pepper Hamilton Talks Tax With the Deal
The M&A Word of the Day® from the Book of Jargon® – Global Mergers & Acquisitions Is Inversion
Our Federal Tax Group finds the sweet spot for corporate inversions. If a U.S. corporation’s shareholders obtain between 50% and 60% of the stock, the exchange could be taxable....more
Generally speaking, a corporation inversion is a process of changing the holding structure of an existing company by transferring all of the existing company’s issued share capital from its shareholders to a new company, in...more
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
In a recently released Chief Counsel Advice Memorandum (the “Memorandum”), the IRS Office of Chief Counsel (International) addressed an interesting and somewhat creative internal financing structure deployed by a taxpayer...more
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
In what may be the first of a series of steps, the government took decisive action today to ensure that shareholders of US companies inverting by merger must pay tax on the transfer of their US company shares if they hold a...more