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Recent IRS anti-inversion proposals: Notice 2014-52

  • Baker Botts LLP
  • -
  • USA
  • -
  • December 17 2014

A corporate transaction that has received considerable publicity in recent months is the so-called "inversion" where a public U.S. company migrates

Tax Court characterizes technology executive’s merger proceeds as ordinary income

  • Mintz Levin Cohn Ferris Glovsky and Popeo PC
  • -
  • USA
  • -
  • November 18 2014

On October 30th, the U.S. Tax Court ruled that a key executive of a technology company acquired by Google for $93 million was required to report a

D reorganization basis regulations finalized

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 1 2014

In November the Treasury finalized a temporary and proposed regulation dealing with the basis of stock of the target corporation in a nondivisive D

Notice 2014-67 gives everyone a new private business use safe harbor

  • Squire Patton Boggs
  • -
  • USA
  • -
  • October 28 2014

Moby Dick is not a book about the whaling industry, The Godfather is not a movie about cannoli, and IRS Notice 2014-67 is not just about accountable

IRS acts to close down “inversions” of US companies

  • RPC
  • -
  • USA
  • -
  • October 24 2014

On 22 September 2014, and with immediate effect, the Internal Revenue Service (IRS) announced measures both to make it more difficult for US

The tax advantages to emerging businesses of utilizing profits interests as equity awards

  • Locke Lord LLP
  • -
  • USA
  • -
  • October 21 2014

When granting equity-based compensation to service providers, pass-through entities, such as partnerships and limited liability companies, have

AbbVie to reconsider inversion deal

  • Steptoe & Johnson LLP
  • -
  • USA
  • -
  • October 15 2014

AbbVie Inc. announced yesterday that its Board of Directors will meet by October 20 to reconsider its recommendation to shareholders to approve a $51

Treasury and IRS issue anti-inversion guidance

  • Cahill Gordon & Reindel LLP
  • -
  • USA
  • -
  • October 14 2014

On September 22, 2014, the Treasury Department (the "Treasury") and the Internal Revenue Service (the "IRS") issued Notice 2014-52 (the "Notice"

Inside M&A - Fall 2014

  • McDermott Will & Emery
  • -
  • USA
  • -
  • October 14 2014

Buyers can acquire unintended and potentially very damaging liabilities together with target business or assets. Analyzing the financial situation of

Tax inversions: administrative and legislative responses

  • Kelley Drye & Warren LLP
  • -
  • USA
  • -
  • October 10 2014

Tax inversions, mergers of U.S. companies with generally smaller foreign companies that result in a new company with headquarters overseas largely to