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Temporary IRS Rules Counter Inversions and Post-Inversion Tax-Avoidance Transactions

by Thomas M. Long | Apr 21, 2016   ()

The IRS recently issued temporary regulations that address transactions that are structured to avoid the purposes of Code Section 7874 and Section 367, as well as certain post-inversion tax-avoidance transactions. These regulations affect certain domestic corporations whose assets are directly or indirectly acquired by a foreign corporation and certain persons related to such domestic corporations and partnerships. The text of the temporary regulations also serves as the text of contemporaneously issued proposed regulations. Read More

Source: Accounting Web
Source: Accounting Web

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