Corporate inversions - Treasury, administration weighing administrative options 

August 5: Treasury Secretary Jack Lew today said that the administration was weighing a broad array of options concerning “corporate inversions”—including what, if any, administrative options may be available.

In an interview with the New York Times, Secretary Lew said that the options being considered could address the economics of corporate inversions, but that a legislative solution would be preferred.

Last week, Stephen Shay, former Deputy Assistant Secretary for International Tax Affairs at Treasury suggested in a Tax Notes article that Treasury could, for example, use its authority under section 385 to recharacterize certain related-party debt as equity as one method to make inversion transactions less appealing.

In late July 2014, the Senate Finance Committee addressed corporate inversions in a hearing that covered a broad range of international tax topics.

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