A Close Look At The Latest Anti-Inversion Guidance

Law360, New York (December 1, 2015, 11:53 AM EST) -- Over the past several years, a number of high-profile transactions have been effectuated or proposed in which a U.S. corporation is technically acquired by a smaller foreign corporation in order to, in part, achieve a more efficient tax profile for the U.S. corporation on a going-forward basis (commonly referred to as an "inversion transaction"). The wave of such inversion transactions has led to considerable debate in the press, Congress and the Obama administration about whether (and how) to curtail the proliferation of such transactions.

On Sept. 22, 2014, the U.S. Treasury Department and the Internal Revenue Service responded by issuing Notice...

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