The Resource Select corporate migration and combination considerations in an ever changing environment - update

Select corporate migration and combination considerations in an ever changing environment - update

Label
Select corporate migration and combination considerations in an ever changing environment - update
Title
Select corporate migration and combination considerations in an ever changing environment - update
Creator
Subject
Language
eng
Summary
The article in issue 3 was intended to highlight key developments in, as well as the evolution of, the world of corporate migrations, "inversions" and other cross-border combinations, with a particular focus on changes in transactional structures, statutory provisions and regulatory and other guidance. Among other things discussed was the "Coordination Rule" for prioritizing application of Code Sec. 367(a) and Code Sec. 367(b) in certain transactions. As indicated, this rule allowed in particular circumstances the shareholder-level tax rule of Code Sec. 367(a) to be "turned off" in favor of the so-called Killer B rules of Code Sec. 367(b). It also contained other relevant rules (e.g., the deemed contribution rule). While the article was in press, the IRS and the Treasury issued Notice 2014-32 (25 Apr. 2014), which alters the priority rule by reducing significantly the ability for taxpayers to turn off the Code Sec. 367(a) shareholder-level tax rule. The Notice also makes other changes
Citation source
In: International tax journal. - Chicago. - Vol. 40 (2014), no. 4 (July-August) ; p. 45-46
http://library.link/vocab/creatorName
  • Hicks, H
  • James, O
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • inversion transaction
  • corporate inversion
  • migration
Label
Select corporate migration and combination considerations in an ever changing environment - update
Instantiates
Publication
Label
Select corporate migration and combination considerations in an ever changing environment - update
Publication

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