Internal Revenue Service July 12, 2018 – Federal Register Recent Federal Regulation Documents

Inversions and Related Transactions
Document Number: 2018-14693
Type: Rule
Date: 2018-07-12
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations that address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain post- inversion tax avoidance transactions. These regulations affect certain domestic corporations and domestic partnerships whose assets are directly or indirectly acquired by a foreign corporation and certain persons related to such domestic corporations and domestic partnerships. This document finalizes proposed regulations, and removes temporary regulations, published on April 8, 2016.