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IRS & Treasury tighten rules on US firms moving to low-tax countries

19 June 2012

Matthew Gilleard - ITR


The IRS and Treasury have released new rules that make it harder for US companies to relocate to low-tax jurisdictions.

The tightening of the rules has come as a response to a series of corporate relocations away from the US, and will require that when a company moves country following a merger, the newly formed company must have 25% of its employees, property and gross income in the new country.

The latest example of a relocation was Eaton Corporation, which is moving its headquarters from Cleveland, Ohio, to Ireland following its acquisition of Dublin-based Cooper Industries.

Failure to comply with the conditions will lead to substantial penalties, but the Eaton move is not...



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