The US Treasury recently issued new regulations to deter corporate ‘inversions’, where a US parented company and a non-US company combine and locate the tax residence of the merged company in a non-US jurisdiction. Joseph Goldman and Anthony Whall (Jones Day) review their impact.
On 4 April 2016 the US Treasury issued significant federal tax regulations in an effort to deter so-called corporate ‘inversions’ where a US parented company and a non-US company combine and locate the tax residence of the merged company in a non-US jurisdiction typically with the US parented company as the larger of the two. The tax regulations adopt and augment administrative guidance issued in September 2014 and November 2015 in the form of IRS notices that had previously sought to deter or prevent such inversions.
The US Treasury has acted because it perceives that: ‘[T]he...
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The US Treasury recently issued new regulations to deter corporate ‘inversions’, where a US parented company and a non-US company combine and locate the tax residence of the merged company in a non-US jurisdiction. Joseph Goldman and Anthony Whall (Jones Day) review their impact.
On 4 April 2016 the US Treasury issued significant federal tax regulations in an effort to deter so-called corporate ‘inversions’ where a US parented company and a non-US company combine and locate the tax residence of the merged company in a non-US jurisdiction typically with the US parented company as the larger of the two. The tax regulations adopt and augment administrative guidance issued in September 2014 and November 2015 in the form of IRS notices that had previously sought to deter or prevent such inversions.
The US Treasury has acted because it perceives that: ‘[T]he...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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