October 6, 2014

On September 22, 2014, the Treasury Department issued Notice 2014-52 (the “Notice”) designed to curb inversion transactions, which are believed to be inconsistent with its purposes of Section 7874 of this Internal Revenue Code of 1986, as amended (its “Code”).

The effective date of the Notice and any Treasury regulations to be promulgated pursuant to the Notice is for any inversion transactions not completed on or before September 22, 2014, the date the Notice was issued.

To view the full alert, click here.