On 22 September 2014, The U.S. Treasury Department issued Notice 2014-52 announcing administrative action against companies that invert by substantially reducing the economic benefit to be gained from inverting and making inversions more difficult to accomplish.
Key actions of the notice include:
- Prevent inverted companies from accessing a foreign subsidiary's earnings while deferring U.S. tax through the use of creative loans, which are known as "hopscotch" loans (Action under section 956…