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Oct. 8 — Companies that invert on or after Sept. 22 could be impacted by the government's next round of guidance to put the brakes on these transactions, as the administration actively considers tightening the reins on earnings stripping, IRS and Treasury Department officials cautioned.
Although that coming guidance will apply prospectively, “the mere fact that somebody inverts on or after Sept. 22 isn't going to grandfather them out of any future guidance,” Daniel M. McCall, special counsel in the Internal Revenue Service Office of Associate Chief Counsel (International), said Oct. 8 during a webinar sponsored by Penn State Law .
Sept. 22 is the date the Treasury and the IRS issued Notice 2014-52, the administration's newest effort to slow a wave of offshore restructurings designed to escape U.S. tax (184 DTR GG-1, 9/23/14).
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