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On November 19, 2015, Treasury issued Notice 2015-79 (the “Notice”), which announces Treasury’s intent to issue regulations reducing the tax benefits available to inverted groups and making it more difficult for some U.S. companies to invert. The Notice, which includes rules governing inversions and post-inversion restructuring, notably does not impose additional limits on earnings stripping. The Notice generally applies to inversions completed after November 18, 2015