Skip to main content

Legal Update

The IRS and Treasury Issue New Anti-Inversion Guidance

25 September 2014
Mayer Brown Legal Update

Following weeks of speculation and anticipation of administrative guidance on corporate inversions, the Internal Revenue Service and the Treasury Department released Notice 2014-52 on September 22, 2014, describing new regulations to be issued by the government to curtail inversion transactions.

The Notice introduces two new sets of rules: (1) rules to prevent taxpayers from avoiding the application of Internal Revenue Code sections 7874 and 367 and (2) rules seeking to reduce or neutralize perceived tax benefits that may be available to inverted corporations.


  • Jason S. Bazar
    T +1 212 506 2323
  • James R. Barry
    T +1 312 701 7169
The Build a Report feature requires the use of cookies to function properly. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently. If you do not accept cookies, this function will not work. For more information please see our Privacy Policy

You have no pages selected. Please select pages to email then resubmit.