IRS: Notice 2015-79 Additional Rules Regarding Inversions and Related TransactionsBy Robert Robillard - 27 novembre 2015
This blogpost originally appeared on rbrt.ca.
Notice 2015-79 Additional Rules Regarding Inversions and Related Transactions was recently released by the U.S. Treasury. It is available here.
It provides more guidance on the anti-inversion rules included in section 7874 of the Internal Revenue Code. Notice 2015-79 expands on the guidance included in Notice 2014-52, Rules Regarding Inversions and Related Transactions.
The library on Transfer Pricing in the United States is available here.
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