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U.S. Chamber of Commerce Files Lawsuit Challenging Rule Allowing IRS to Disregard Recent Acquisitions in Determining Inversion Thresholds

08 August 2016

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Proposed Changes

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United States

The U.S. Chamber of Commerce has announced that it has filed a lawsuit along with the Texas Association of Business that challenges the so-called Multiple Acquisition Rule issued by Treasury in April 2016 that applies in relation to the inversion thresholds under Section 7874. The complaint includes that the Multiple Acquisition Rule violates the Administrative Procedure Act (APA), and seeks an order and judgment setting aside the Rule. The Multiple Acquisition Rule Under Section 7874, an inverted company will be treated as a U.S. domestic company for tax purposes if there is a continuity of ownership for U.S. shareholders of...