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Legal Update

Treasury’s New Anti-Inversion Regulations: Do They Go Too Far?

7 April 2016
Mayer Brown Legal Update

The Proposed and Temporary Regulations Will Affect Future Tax Planning for All Multinational Businesses

On April 4, the US Treasury and the IRS issued extensive proposed and temporary regulations described as curbing inversions and addressing earnings stripping. Although the regulations have been publicized as targeting inversions, the most noteworthy aspect is the proposed rules referring to the recharacterization of intercompany debt as stock for US tax purposes. These proposed rules (not limited to inverted companies) could have far-reaching effects on US and foreign companies, overturning the long-standing treatment of certain intercompany debt arrangements.


  • James R. Barry
    T +1 312 701 7169
  • Jason S. Bazar
    T +1 212 506 2323
  • Steven D. Garden
    T +1 312 701 7830
  • Brian W. Kittle
    T +1 212 506 2187
  • Thomas Kittle-Kamp
    T +1 312 701 7028
  • Warren S. Payne
    Legal Professional / Consultant, Senior Advisor
    T +1 202 263 3831
  • Scott M. Stewart
    T +1 312 701 7821
  • Lucas Giardelli
    T +1 212 506 2238
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