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Jeff Samuels Quoted on New Inversion Rules in The Wall Street Journal

April 7, 2016

Tax partner Jeffrey Samuels was quoted in an April 7 article in The Wall Street Journal, titled "New Inversion Rules Draw Concerns Outside U.S." The article discusses newly proposed Treasury Department regulations that are designed to limit the ability foreign corporations to push intercompany debt into their US subsidiaries in order to reduce US taxes. Although the new rules emerge in the context of the concern about inversion transactions, they are far broader than that in scope.  Jeff is quoted as suggesting that foreign governments may object to the proposed regulations as beyond the boundaries of what is allowed under treaty relationships.

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