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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.
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