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Transatlantic Tax Issues

Continuing our series on transatlantic tax issues Graham Samuel-Gibbon and Justin Stalls of Latham & Watkins consider the potential impact for UK shareholders of the US anti-inversion rules
The UK Government is seeking to stem the tide of corporate migrations out of the UK with the introduction of the new rules on the taxation treatment of foreign dividends which will exempt from corporation tax many dividends received from foreign companies. It is therefore timely to consider one of the measures introduced in the US to prevent tax-driven exits from the US and the impact that these measures can have in the UK.
The US took a 'stick' rather than 'carrot' approach to migrations seeking to reduce US tax with the introduction of anti-inversion rules in 2004. These rules are...

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