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Content Type: Publications Tagged: 'David Brinton'

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US Tax Reform: Who comes out ahead?

21 December 2017


On December 20, 2017, Congress voted to enact the most sweeping US tax reform bill in decades. The Tax Cuts and Jobs Act will reduce business tax rates and revamp the US international tax system. While the President may not sign the Act until January 2018,...

New Spin-off Rules

21 July 2016


On July 14 and 15, 2016, the Treasury and the IRS issued new guidance on the requirements for tax-free corporate "spin-off" transactions. The guidance includes proposed regulations which would make it more difficult to successfully execute a tax-free...

Inversions: Tough New Rules

6 April 2016


On Monday, April 4, 2016, the Treasury and the IRS issued temporary and proposed regulations which make it harder to successfully complete an inversion transaction, and to reduce an inverted US company's taxes through the use of intercompany debt.

Inversions: The Next Round

23 November 2015


On Thursday, November 19, 2015, the Treasury and the IRS issued Notice 2015-79 (the "Notice"), which builds on previous attempts to make inversions harder to accomplish and to reduce the economic benefit of inverting.  The guidance described in the...

Inversions: Is This the End?

24 September 2014


On Monday, September 22, 2014, the Treasury and IRS issued Notice 2014-52, which makes corporate inversions more difficult to accomplish and diminishes the economic benefit of inverting.  The guidance described in the Notice will apply to inversions completed...