Shapiro Quoted in The Wall Street Journal on Treasury Rule Changes’ Potential Effect on Pfizer-Allergan Merger

Shapiro Quoted in The Wall Street Journal on Treasury Rule Changes’ Potential Effect on Pfizer-Allergan Merger
Pfizer Heads for Fight With U.S. on Tax-Saving Allergan Deal
November 19, 2015
Richard Rubin, Jonathan D. Rockoff and Dana Cimilluca
The Wall Street Journal
Partner David Shapiro was quoted in this article about the new U.S. Treasury rules that aim to deter the use of corporate tax inversions, which companies employ to reduce their tax bills when merging with companies incorporated overseas. Treasury Secretary Jacob Lew has said the restrictions were needed because U.S. companies were “taking advantage of an environment that allows them to move their tax residence overseas in order to avoid paying taxes in the United States without making significant changes in the nature of their overall business operations.”
 
In light of the proposed merger between U.S.-based Pfizer and Dublin-based Allergan, the article examines whether the new rules will impact their plans. David, who was the chair of the ABA Tax Section Committee on U.S. Activities of Foreigners and Tax Treaties, and the lead author of ABA Tax Section comments to anti-inversion rules announced in 2014, said, “Some of the [Treasury] changes are significant, but honestly I don’t see it affecting Pfizer-Allergan too badly.”
 
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