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New Treasury Notice Squeezes the Juice From Some Corporate Inversions – How Are You Impacted by the New Rules?

James M. Wickett

James M. Wickett,

Washington, D.C.

John S. Stanton

John S. Stanton,

Washington, D.C.

Jason Kaplan

Jason Kaplan,

New York

Robert Glennon

26 September 2014
In response to a record number of pending "inversion" transactions and the perceived potential loss of tax revenue, the U.S. Treasury Department, on September 22, 2014, issued Notice 2014-52, announcing and detailing to-be-issued regulations intended to (i) make it more difficult to accomplish an inversion, and (ii) reduce the perceived tax advantages of doing so with respect to the untaxed earnings of foreign subsidiaries.
James M. Wickett

James M. Wickett,

Washington, D.C.

John S. Stanton

John S. Stanton,

Washington, D.C.

Jason Kaplan

Jason Kaplan,

New York

Robert Glennon

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