Sullivan & Cromwell Discusses U.S. Tax Consequences of EU State Aid Recoupment

By Michael Orchowski, Andrew S. Mason, Andrew P. Solomon and Eric S. Wang October 3, 2016 by Andrew P. Solomon

On September 15, the IRS and Treasury Department proposed, in Notice 2016-52 (the “Notice”), new rules that limit the ability of U.S. multinational groups to claim credits against U.S. taxes for significant foreign tax adjustments (i.e., …

Sullivan & Cromwell discusses New Anti-Inversion Notice

By Donald L. Korb, Andrew S. Mason, Andrew P. Solomon, David C. Spitzer, Davis J. Wang, S. Eric Wang, David J. Passey and Assaf Y. Prussak October 1, 2014 by Andrew P. Solomon

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 …

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Sullivan & Cromwell Discusses U.S. Tax Consequences of EU State Aid Recoupment

Sullivan & Cromwell discusses New Anti-Inversion Notice