Treasury Urges 5th Circ. To Reinstate Anti-Inversion Rule

Law360 (March 19, 2018, 7:15 PM EDT) -- The U.S. Department of the Treasury urged the Fifth Circuit in an appeal filed Friday to resurrect a temporary rule invalidated by a Texas federal court after it sank a planned $160 billion merger between Pfizer Inc. and Irish counterpart Allergan PLC, saying that it had fulfilled its obligations in promulgating the rule.

Treasury and the Internal Revenue Service said that the lower federal court in Texas was wrong to have concluded that the anti-inversion rule — meant to deter U.S. companies from merging with foreign rivals to avoid U.S. taxes and take advantage of lower tax rates overseas — had...

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