On October 13, 2016, the IRS and the Treasury Department issued new rules largely designed to prevent highly related corporate taxpayers from claiming the tax benefits of “earnings stripping,” or the payment of excessive...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
On September 22, 2014, the United States Department of the Treasury and the Internal Revenue Service issued a Notice (Notice 2014-52) that limit "inversion" transactions and their potential tax benefits. In general, an...more