Treasury officials said last week that the agency is still working on more guidance aimed at stemming the flow of U.S. companies merging with foreign companies and reorganizing as foreign entities.

The IRS first addressed the issue on Sep. 22 with Notice 2014-52. The guidance tightens the rules under Section 7874, which generally prevent a U.S. company from being treated as foreign entity after a merger in which the foreign shareholders own less than 20% […]

In March 2014 the Russian Ministry of Finance published a draft anti-offshore law which is currently submitted for consideration by The State Duma (parliament) with the decision expected to be made by the end of 2014. Russia is aiming to clamp down on the use of foreign offshore tax shelters in a new tax policy as part of President Putin’s “deoffshorisation” campaign which was launched in 2012. With an estimated $800bn – $1trillion worth […]