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Treasury Department and IRS Issue Long-Awaited Inversion Guidance
Lester W. Droller,Andrew M. Eisenberg,Andrew M. Levine,Robert A. Profusek,Raymond J. Wiacek, September 25, 2014
On September 22, 2014, the U.S. Treasury Department and the IRS issued long-awaited inversion guidance in the form of Notice 2014-52. The Notice sets forth rules that are generally effective for acquisitions completed on or after September 22, 2014, and will be included in regulations that will be...
New FATCA Guidance
Lodewijk P.W. Berger,Lyda Stone,Raymond J. Wiacek, May 16, 2014
On April 2, the U.S. Treasury released Announcement 2014-17 under the Foreign Account Tax Compliance Act, sections 1471 through 1474 of the Internal Revenue Code ("FATCA"), broadening the scope of when an intergovernmental agreement ("IGA") is considered to be in effect and...
Belgium Modifies its Notional Interest Deduction Regime to Comply with EU Law
Lodewijk P.W. Berger,Lyda Stone,Raymond J. Wiacek, May 15, 2014
In 2008, Argenta Spaarbank NV—a Belgian savings bank operating a branch in The Netherlands—challenged the validity of the exclusion of the net book value of its Dutch branch from the computation basis for the notional interest deduction ("NID"). The principal argument of...