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The Internal Revenue Service issued a notice on Thursday, November 19th indicating impending rules to crack down on so-called inversion transactions, a deal structure that sees a U.S. corporation merge with a foreign company and relocate its tax residence in a foreign jurisdiction in an effort to trim its U.S. corporate tax burden.
Loeb & Loeb partner John Settineri is quoted on the impact of the latest rules, stating: “While the changes are geared to thwart some of the most abusive inversion structures and post-inversion tax avoidance, they are far from enough to stop inversions altogether.”
Click here to read the article on the Law360 website.