Layla Asali Quoted on Corporate Inversions in Bloomberg BNA's Daily Report for Executives

"IRS Requests Feedback on Stock/Asset Disparity in Corporate Acquisitions"
Bloomberg BNA's Daily Report for Executives
03.13.14Layla Asali was quoted on the Obama administration's fiscal year 2015 budget proposal regarding corporate inversions. Her comments were part of a panel discussion with Treasury Department and IRS officials regarding new Temporary Regulations under section 7874, the anti-inversion statute, and the budget proposal. The proposal put forth in the Treasury Green Book would create a new U.S. business activities and management test. Asali asked whether the government is looking at the domestic or foreign firm's management. "It raises a lot of questions about what is the policy it's really getting at," she said, adding that there could be perfectly reasonable business reasons, under pre-transaction characteristics, for a foreign acquiring company to end up being managed and controlled in the United States. Treasury officials said the test is looking for situations where the domestic target company claims to be a foreign corporation but the management of the domestic target company "calls the shots after the transaction."
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