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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
  • Lee Morlock
    T +1 312 701 8832

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