Treasury Issues Temporary Regulations on Inversions
On 4 April 2016, the US Department of Treasury issued extensive temporary regulations (the Temporary Regulations) addressing inversion transactions and post-inversion planning. The Temporary Regulations finalize the rules announced in Notice 2014-52 (the 2014 Notice) and Notice 2015-79 (the 2015 Notice), with a few modifications. The Temporary Regulations also introduce new limitations on inversions, including limitations on multiple-step acquisitions and "serial" acquisitions. As discussed in a prior Client Alert, the 2014 Notice and the 2015 Notice left many questions unanswered, were based on broad assumptions, and raised concerns regarding the scope of Treasury's regulatory authority.