On December 13, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations (the “Regulations”) regarding the base erosion and anti-abuse tax (generally referred to as the...more
On July 11, 2018, the Treasury Department and the IRS published final Treasury regulations on inversion transactions (the “Final Regulations”). The Final Regulations substantially adopt the temporary Treasury regulations...more
The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...more
On July 15th, the IRS released Rev. Proc. 2016-40 (the “Rev. Proc.”) removing a recent “no-rule” area with respect to transactions undertaken in anticipation of a spin-off involving high vote/low vote stock classes for the...more
On July 14, 2016, the Treasury Department and the IRS issued proposed regulations under Section 355 on spin-off transactions (the “Proposed Regulations”) that provide guidance with respect to the spin-off device prohibition...more
On April 4, 2016, the Treasury Department and the IRS issued temporary regulations under Section 7874 on inversion transactions that added some new restrictions and implemented provisions previewed in two prior IRS notices...more
The Treasury Department and the IRS released Notice 2014-52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of...more
On December 4, 2013, the Treasury Department and the Internal Revenue Service (the “IRS”) released new final and proposed regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more