US-INVERSIONS

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.

Joseph Goldman

Anthony Whall

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.

Mitchell R. Kops

Kristin Konschnik

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

Sara Luder

Sara Luder (Slaughter and May) explains why politicians should think carefully about the consequences of proposed tax changes

Can the trend for tax inversions survive an assault from the US Treasury department? Adam H Rosenzweig, professor of law at Washington University School of Law, assesses the situation.

Jonathan Cooklin (partner) and Dominic Foulkes (associate) of law firm Davis Polk comment on the current trend of US corporate inversions.