The Government Strikes Back -- New IRS Notice Strengthens Anti-Inversion Rules

7 Pages Posted: 9 Jul 2015

Date Written: January 1, 2015

Abstract

Inversion or expatriation transactions are often prompted by financial institutions, such as private equity owners and hedge funds that own or control companies in which they have invested and that desire to reduce U.S. corporate taxes they must pay. This article explains the basic steps and perceived tax benefits to U.S. corporations engaging in inversion transactions, and describes both the current statutory limitations contained in the Internal Revenue Code to prevent such inversions and a recently announced Internal Revenue Service (IRS) plan to make inversions more difficult to achieve. Finally, the article discusses the appropriateness of the new IRS plans and suggests other ways to make such inversions less attractive.

Suggested Citation

Appel, Alan, The Government Strikes Back -- New IRS Notice Strengthens Anti-Inversion Rules (January 1, 2015). Journal of Taxation and Regulation of Financial Institutions, Vol. 28, No. 19, 2015, Available at SSRN: https://ssrn.com/abstract=2628220

Alan Appel (Contact Author)

New York Law School ( email )

185 West Broadway
New York, NY 10013
United States

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