On 19 November 2015, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued Notice 2015-79 on additional actions to make it more difficult for companies to invert and to reduce the tax benefits companies that do invert.
The additional actions to make it more difficult to invert apply to deals closed on or after 19 November 2015 and include:
- Strengthening the requirement that the former owners of a U.S. company own less than 80% of the new combined entity by:
- Disr…