Law360, New York (January 2, 2015, 2:14 PM EST) -- Although the Internal Revenue Service has more than 300 projects on its priority guidance plan, limited resources will force the agency to prioritize the regulations it issues in 2015, including potential rules on inversion transactions and a possible major rewrite of proposed 501(c)(4) rules.
In September, the U.S. Department of the Treasury and the IRS issued Notice 2014-52 saying rules were in the works to reduce the tax benefits of corporate inversions. The new rules would contain several changes to ownership requirements and prevent companies from using "hopscotch loans" to bypass a hefty 35 percent U.S. corporate tax rate when...
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