Sullivan & Cromwell discusses New Anti-Inversion Notice

SUMMARY

On September 22, 2014, the Internal Revenue Service (the “IRS”) and the Treasury Department (the “Treasury”) issued Notice 2014-52 (the “Notice”) announcing that the Treasury and the IRS intend to issue regulations that will address inversion transactions and certain post-inversion transactions that the IRS and the Treasury characterize as tax avoidance transactions. According to the Treasury, the forthcoming regulations are intended to reduce the potential tax savings that could be extracted from inversion transactions and generally tighten the rules on cross-border mergers. The Notice is generally applicable to acquisitions completed on or after September 22, 2014 (even if completed … Read more