First Shoe Drops for Corporate Inversions

Notice 2014-52, released by the US Treasury Department on September 22, 2014, is intended to disrupt, and in some cases prevent, so-called corporate inversion transactions that have not been completed prior to the notice’s release.

Although the notice includes very detailed rules, it very generally takes a two-pronged approach to discourage inversions after September 21, 2014.

Dentons’ Tax team explores the implications of Notice 2014-52 on cross-border acquisitions or mergers.

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John Harrington

About John Harrington

John Harrington is the co-leader of Dentons' US Tax practice, which was recognized by The Legal 500 in 2020 for outstanding work in international and non-contentious tax. Recognized by Chambers Global as a Notable Practitioner, he advises clients on inbound and outbound transactional and compliance issues; international tax legislative, regulatory and treaty matters; and a variety of domestic tax issues.

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Timothy Santoli

About Timothy Santoli

Timothy Santoli is a member of Dentons' Taxation practice. He has expertise in a wide variety of domestic and international federal income tax matters, including domestic and cross-border tax-planning strategies as well as taxable and tax-free mergers, acquisitions and dispositions of domestic and foreign corporations.

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Andrea Sharetta

About Andrea Sharetta

Andrea Sharetta is a member of Dentons' Tax practice. She has expertise in federal income tax matters, including taxable and tax-free mergers, acquisitions, dispositions and other restructurings; bankruptcy and insolvency reorganizations; taxation of consolidated groups of corporations; and corporate joint ventures, with a concentration on cross-border tax planning and taxation of nonresidents.

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Marc Teitelbaum

About Marc Teitelbaum

Marc Teitelbaum is the former chair of Dentons' Tax practice, which was recognized by The Legal 500 in 2020 for outstanding work in international and non-contentious tax. Marc has been involved in advising public companies, underwriters and investment funds principally in the following areas: acquisition and disposition of domestic and foreign corporations whether taxable or tax-free transactions; the US tax consequences of foreign operations and foreign joint ventures, in particular, multinational manufacturing and sales operations; debt and equity financings; and investment strategies in partnership form, including tax- and accounting-advantaged structured domestic and cross-border financing arrangements.

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