IRS Notice targets repatriation of offshore earnings

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December 2016

Overview

The IRS and Treasury target cross-border triangular reorganizations and inbound nonrecognition transactions in Notice 2016-73 (the ‘Notice’).  The Notice, issued December 2, 2016, is the sixth set of rules that the government issued in the last decade regarding these transactions and is the latest salvo in its campaign against repatriation of offshore cash. Companies considering such transactions should carefully contemplate the Notice's potential application, as it states that future regulations will be effective as of its issuance date.

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Tim Anson

ITS Partner, PwC US

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