The Resource New Temporary Regulations restrain inversions

New Temporary Regulations restrain inversions

Label
New Temporary Regulations restrain inversions
Title
New Temporary Regulations restrain inversions
Creator
Subject
Language
eng
Summary
This article analyzes the new Temporary Regulations that deal with certain transactions that are structured to avoid the anti-inversion provisions under Code Sec. 7874. Section I provides background regarding Code Sec. 7874. Section II analyzes the new rule that applies when the acquisition of the domestic entity involves multiple steps. Section III covers the Temporary Regulations that impact the calculation of the ownership percentage, which is important for applying the anti-inversion rules under Code Sec. 7874. Section IV considers the impact of transferred stock on the expanded affiliated group (EAG) rules that disregard certain stock from the ownership percentage. Section V discusses the changes to the substantial business activities exception under Code Sec. 7874. Section VI concludes that the Temporary Regulations will curtail inversions of U.S. companies into foreign corporations, but that inversion activity will continue without anti-inversion legislation
Citation source
In: Taxes - the tax magazine. - Riverwoods. - Vol. 94 (2016), no. 10 ; p. 25-50
http://library.link/vocab/creatorName
Doering, J.A
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • corporate inversion
  • anti-inversion
Label
New Temporary Regulations restrain inversions
Instantiates
Publication
Label
New Temporary Regulations restrain inversions
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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