New U.S. Treasury Regulations Implement Inversion Rules, Take Aim at "Serial Inverters" and Earnings Stripping

On April 4, 2016, the U.S. Treasury Department and the Internal Revenue Service issued proposed and temporary regulations (the “Inversion Regulations”) addressing so-called inversion transactions. In general, the Inversion Regulations: Adopt, with certain modifications, the rules described in Notice 2014-52 (the “First Notice”) and Notice 2015-79 (the “Second Notice”); and Add a new (and unexpected) rule aimed at so-called (by the Treasury) “serial inverters.” Read more. (Subscription required.)