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On November 19, 2015, the US Internal Revenue Service and the Treasury Department issued Notice 2015-79, announcing their intention to expand on previously issued guidance concerning inversions and post-inversion transactions. The latest Notice introduces three types of rules: (1) rules to prevent taxpayers from avoiding the application of Internal Revenue Code section 7874 to certain acquisition transactions, (2) rules seeking to reduce or neutralize tax benefits perceived to be available through post-inversion transactions, and (3) changes to clarify or provide relief under certain rules contained in Notice 2014-52.
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