More Than One Inversions Notice Likely, Earnings Stripping May Wait

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Nov. 5 —  The government is likely to put out more than one additional notice on inversions in addition to regulations implementing the anti-inversion Notice 2014-52—and earnings stripping may wait beyond that first round of additional guidance, a Treasury Department official said.
The administration is still deciding whether and when it will address earnings stripping, and that action could come following the first additional notice, Douglas Poms, senior counsel in Treasury's Office of International Tax Counsel, said Nov. 5.
“We might do something in that space in the next notice or the one after that,” he said at the Fall Tax Division Meeting of the American Institute of CPAs. “We're not committed to doing it in the next one.”