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Inversion

Delphi wins IRS inversion challenge & so is not treated as U.S. corporation

Delphi wins IRS inversion challenge & so is not treated as U.S. corporation

In a filing with the U.S. Securities and Exchange Commission (SEC), Delphi Automotive PLC (Delphi) announced that it is has won an appeal with IRS allowing the company to be treated as a U.K. tax resident for U.S. federal tax purposes. IRS had asserted that Delphi should be treated as a U.S. company under Code […]

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Obama tax inversion rules may overstep authority

Obama tax inversion rules may overstep authority

WASHINGTON (Reuters) – President Barack Obama’s proposed rules to stop U.S. companies from reincorporating abroad, if only on paper, to avoid U.S. income taxes appear to overstep legal authority, a top Republican lawmaker said on Friday. Representative Kevin Brady said his staff is scrutinizing the rules, which were unveiled last week by the U.S. Treasury […]

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Inversion rules will hit boutique M&A advisors hardest

Inversion rules will hit boutique M&A advisors hardest

NEW YORK (IFR) – Boutique advisory firms will lose out on millions of dollars in fees if the US Treasury Department’s latest proposed rules on tax-avoiding corporate mergers causes more M&A deals to fall apart. The clamp down – aimed at curbing deals in which companies move overseas to cut taxes – threw a number […]

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Tax rules that killed Allergan-Pfizer deal may be hard to challenge

Tax rules that killed Allergan-Pfizer deal may be hard to challenge

(Reuters) – U.S. tax rules are more difficult to sue over than other regulations that emanate from Washington, presenting a challenge to anyone considering a lawsuit over an Obama administration plan to discourage deals known as inversions, tax lawyers say. Business trade groups have frequently gone to court since President Barack Obama took office in […]

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Temporary regs counter inversions and post-inversion tax avoidance transactions

Temporary regs counter inversions and post-inversion tax avoidance transactions

T.D. 9761, 04/05/2016, Reg. § 1.304-7T , Reg. § 1.367(a)-3T, Reg. § 1.367(b)-4T, Reg. § 1.956-2T, Reg. § 1.7701(l)-4T , Reg. § 1.7874-1T, Reg. § 1.7874-2T , Reg. § 1.7874-3T, Reg. § 1.7874-4T, Reg. § 1.7874-6T, Reg. § 1.7874-7T, Reg. § 1.7874-8T , Reg. § 1.7874-9T, Reg. § 1.7874-10T , Reg. § 1.7874-11T, Reg. § […]

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Tax Experts Weigh in on Difficulties of Challenging Anti-Inversion & Earnings Stripping Regs

Tax Experts Weigh in on Difficulties of Challenging Anti-Inversion & Earnings Stripping Regs

Corporate inversions are back in the news this week following the Treasury Department’s release of temporary regs aimed at curbing the practice. Treasury also issued proposed regs aimed at the practice of “earnings stripping.” The regs received a mixed reaction, as expected, with some questioning whether the rules exceed Treasury’s authority. U.S. tax rules are […]

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President and Treasury update plan for dramatic business & international tax reform

President and Treasury update plan for dramatic business & international tax reform

The President’s Framework for Business Tax Reform: An Update. One day prior to the issuance of major corporate inversion regs, the Administration and Treasury Department released a joint report titled “The President’s Framework for Business Tax Reform: An Update.” In addition to providing the President’s vision for tax reform, the report includes recent figures to […]

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Obama urges Congress to take action on corporate tax reform

Obama urges Congress to take action on corporate tax reform

WASHINGTON (Reuters) – U.S. President Barack Obama on Tuesday urged Congress to take action to stop U.S. companies from taking advantage of tax loopholes that allow them to avoid paying taxes. “When companies exploit loopholes like this… it sticks the rest of us with the tab and it makes hard-working Americans feel like the deck […]

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U.S. House Democrats introduce bill to curb company tax inversions

U.S. House Democrats introduce bill to curb company tax inversions

WASHINGTON (Reuters) – Two leading U.S. House Democrats introduced legislation on Tuesday intended to curb corporate tax inversion deals by preventing companies from lowering the effective tax rates of U.S. business operations after moving their headquarters overseas. A bill, authored by the top Democrats on the House Ways and Means and Budget Committees, would limit […]

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U.S. Johnson Controls announces tax inversion with acquisition of Irish Tyco

U.S. Johnson Controls announces tax inversion with acquisition of Irish Tyco

Johnson Controls Inc., a U.S. maker of car batteries and heating and ventilation equipment, announced on Monday that it had agreed to acquire Ireland-based Tyco International Plc in a $16.5 billion deal, effectively shifting its headquarters out of the U.S. in a so-called corporate inversion. Although IRS issued a second round of administrative guidance last […]

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Clinton “exit tax” to take aim at companies’ inversion deals

Clinton “exit tax” to take aim at companies’ inversion deals

WASHINGTON (Reuters) – U.S. Democratic presidential candidate Hillary Clinton will announce a planned crackdown on corporations that shift profits overseas, including a new “exit tax” against so-called inversion deals, her campaign said on Monday. Clinton will call for spending the revenue raised by her proposed tax to boost manufacturing jobs in the United States, the […]

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Clinton aims to stop ‘earnings stripping’ to curb inversion deals

Clinton aims to stop ‘earnings stripping’ to curb inversion deals

WATERLOO, Iowa (Reuters) – U.S. Democratic presidential candidate Hillary Clinton will continue her push to crack down on companies that shift profits overseas, at a campaign stop on Wednesday in Iowa, where she will unveil her plan to rein in the practice, known as earnings stripping. Clinton is spending this week detailing how she will […]

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IRS’s anti-inversion guidance makes inverting more difficult, but won’t solve problem

IRS’s anti-inversion guidance makes inverting more difficult, but won’t solve problem

Notice 2015-79, 2015-49 IRB U.S. Department of the Treasury, Fact Sheet: Additional Treasury Actions to Rein in Corporate Tax Inversions (11/19/2015). IRS has issued a second round of guidance, in the form of a Notice and accompanying fact sheet, as part of its continuing efforts to crack down on corporate inversions. The new Notice, similar […]

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U.S. Treasury to tighten corporate tax inversion rules

U.S. Treasury to tighten corporate tax inversion rules

WASHINGTON (Reuters) – The U.S. Treasury Department this week will clamp down further on tax-avoiding “inversion” deals done by U.S. companies with foreign rivals, according to a letter obtained by Reuters on Wednesday. With a major inversion deal in the works between U.S. drug maker Pfizer Inc and smaller Irish competitor Allergan Plc, Treasury said […]

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Potential Pfizer-Allergan merger brings corporate inversions back into the spotlight

Potential Pfizer-Allergan merger brings corporate inversions back into the spotlight

U.S. pharmaceutical company Pfizer Inc. and Irish Botox maker Allergan Plc have publicly indicated that they are engaged in “friendly” merger talks, reflecting Pfizer’s second major attempt in as many years to shift its headquarters out of the U.S. in a so-called corporate inversion. Although IRS issued administrative guidance last year in efforts to make […]

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Pfizer-Allergan puts focus on U.S. tax inversion rules

Pfizer-Allergan puts focus on U.S. tax inversion rules

(Reuters) – The proposed corporate tie-up between Pfizer Inc and Allergan Plc, both drug makers, is refocusing attention in Washington on tax-driven corporate inversion transactions. U.S.-based Pfizer moved last week to acquire Ireland’s Allergan. Details of their deal were still unavailable, but the companies were said to be eyeing a tax inversion structure. WHAT IS […]

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Washington Alert – DHS investigates inverted corporations; IRS Whistleblower Office receives lots of attention; U.S. & Vietnam sign accord; U.S. & India sign IGA; JCT Report on Excise Taxes

Washington Alert – DHS investigates inverted corporations; IRS Whistleblower Office receives lots of attention; U.S. & Vietnam sign accord; U.S. & India sign IGA; JCT Report on Excise Taxes

A bicameral group of seven Democrats on July 9 called on the chief watchdog of the Department of Homeland Security (DHS) to investigate the possible violation of “multiple federal prohibitions on contracting with inverted corporations.” (Letter to John Roth, Office of Inspector General, Department of Homeland Security) The letter referred to a recent article which […]

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GE announces plan to repatriate overseas funds & trigger $6 billion tax bill

GE announces plan to repatriate overseas funds & trigger $6 billion tax bill

General Electric (GE) has announced that, as part of a larger restructuring plan, it will repatriate to the U.S. $36 billion of cash currently residing overseas and incur a $6 billion tax bill—a move that many in the tax world are surprised by given GE’s reputation for paying a famously low effective corporate income tax […]

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Surge In Corporate Spin-Offs May Lead To Update Of Legal Guidance

Surge In Corporate Spin-Offs May Lead To Update Of Legal Guidance

The increase in corporate spin-offs in recent years is expected to continue for the foreseeable future, and SEC staffers are considering whether the hot dealmaking environment is enough of a reason to update a piece of interpretive guidance from the late 1990s. The guidance explains the criteria companies have to meet in order to divest […]

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Chiquita inversion slips on cash appeal

Chiquita inversion slips on cash appeal

NEW YORK (Reuters Breakingviews) – Chiquita shareholders got yellow and chose green. They voted down a stock deal to acquire Irish produce distributor Fyffes, a decision that led the U.S. banana company on Monday to agree to sell to Brazilian buyers for about $680 million in cash instead. Ailing arbitrageurs, a revolt against tax-driven mergers […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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