Kirkland Alert Kirkland & Ellis LLP

U.S. Treasury and Internal Revenue Service Issue New Anti-Inversion Guidance

Over the past several years, a number of high-profile transactions have been effectuated or proposed in which a U.S. corporation is technically acquired by a smaller foreign corporation in order to, in part, achieve a more efficient tax-profile for the U.S. corporation on a going forward basis (commonly referred to as an “inversion transaction”).