New IRS Crackdown Not Enough To Halt Inversion Deals

Law360, New York (November 20, 2015, 7:35 PM EST) -- The Internal Revenue Service's latest move to crack down on so-called inversion transactions will limit some flexibility and curb certain post-closing benefits, but the upcoming rule changes are not enough to put a stop to tax-motivated deal structures like the one Pfizer is said to be mulling, experts say.

The IRS issued a notice Thursday signaling forthcoming rules that aim to further thwart inversions, a deal structure that sees a U.S. corporation merge with a foreign company and relocate its tax residence in a foreign jurisdiction in an effort to trim its U.S. corporate tax burden.

The upcoming changes will require...

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