The US IRS on the Department of the Treasury on July 12 issued final tax regulations addressing inversion transactions.
The guidance addresses transactions that are structured to avoid the purposes of sections 7874 and 367 and certain post-inversion tax avoidance transactions.
The guidance finalizes proposed and temporary regulations issued April 8, 2016. Some of this guidance was finalized January 18, 2017. The newly issued final regulations adopt the remaining 2016 regulations but make several changes.
The Service noted that the majority of the comments submitted by stakeholders supported the 2016 regulations.
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