Daily Tax Update - January 25, 2016: Johnson Controls Announces Inversion Transaction With Tyco

Johnson Controls Announces Inversion Transaction with Tyco:  Today, Johnson Controls, Inc. and Tyco International plc announced that they had entered into a definitive merger agreement.  Under the terms of the proposed transaction, the businesses of Johnson Controls and Tyco would be combined under Tyco International plc, which would be renamed “Johnson Controls plc.”  Upon the closing of the transaction, the combined company is expected to maintain Tyco’s Irish legal domicile.  Johnson Controls’ shareholders would own approximately 56% of the equity of the combined company.  The announcement states that the transaction is expected to create at least $150 million in annual tax savings.

Miscellaneous Guidance Released: Proposed regulations would increase the user fee for the special enrollment examination to become an enrolled agent.