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Tax Law Roundup current law developments in U.S. taxation

Tag Archives: inversions

IRS Issues More Anti-Inversion Rules

Posted in International

Following on its prior Notice 2014-52 anti-inversion guidance, the IRS has issued new Notice 2015-79 to further limit (i) inversion transactions that are contrary to the purposes of the Section 7874 anti-inversion rules and (ii) the benefits of post-inversion tax avoidance transactions.  The Notice also describes corrections and clarifications to the prior Notice 2014-52.  According… Continue Reading

Treasury Releases Select Draft Provisions for Next U.S. Model Income Tax Treaty

Posted in International, treaty

The Treasury Department announced draft changes for the U.S. Model Income Tax Treaty — the baseline text used by the Treasury Department when it negotiates tax treaties. The current U.S. Model was last updated in 2006. The proposed changes in the draft provisions are intended to combat so-called Base Erosion or Profit Shifting (BEPS), which… Continue Reading