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Adobe PDFIRS and Treasury Issue Long-Awaited Guidance on Corporate Inversions and “Disqualified Stock”
James R. Barry, Jason S. Bazar, Michael K. Marion, Lee Morlock; Mayer Brown LLP;
Legal Alert/Article
January 31, 2014, previously published on January 27, 2014
On January 16, 2014, the Internal Revenue Service (the “IRS”) and the Treasury Department (the “Treasury”) issued longawaited temporary and proposed regulations under Code section 7874 relating to corporate inversions (the “Regulations”).


HTMLNew Proposed Regulations Treat Credit Default Swaps as Notional Principal Contracts
James R. Barry, James E. Clegg, Michael K. Marion, Russell E. Nance; Mayer Brown LLP;
Legal Alert/Article
October 14, 2011, previously published on October 13, 2011
The US Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations on September 16, 2011 (the “proposed regulations”) that, if finalized, will treat credit default swaps (CDSs) and certain other swaps...


Adobe PDFSignificant Revisions to US International Tax Rules
Rafic H. Barrage, James R. Barry, Kenneth Klein, Michael K. Marion, Arthur C. Walker; Mayer Brown LLP;
Legal Alert/Article
August 31, 2010, previously published on August 25, 2010
The Education Jobs and Medicaid Assistance Act of 2010 (Pub. L. No. 111-226) (the “Act”) became law on August 10, 2010. While the Act’s primary purpose is to provide financial assistance to US states for education and Medicaid spending, several international tax provisions were...