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ANTI-INVERSION-RULES


With the UK’s continuing attractiveness as a holding company tax jurisdiction, Jonathan Cooklin and Dominic Foulkes (Davis Polk) consider the scope of technical UK tax issues that have a direct bearing on the drafting of merger agreements and related documents which implement these transactions.
 
The US Treasury recently issued new regulations to deter corporate ‘inversions’, where a US parented company and a non-US company combine and locate the tax residence of the merged company in a non-US jurisdiction. Joseph Goldman and Anthony Whall (Jones Day) review their impact.
 
Chris Morgan (KPMG) reviews the latest developments in the international tax world.
 

President Obama has proposed a levy for US corporations on profits located abroad, which are not repatriated to the US. Kristin Konschnik and Mitchell R. Kops (Withers) consider the proposals and what effect they may have in practice

Why might an American multinational wish to migrate? Tim Sanders and Eric Sensenbrenner explain

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