Final regulations, temporary regulations, and removal of temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2018-07-12
Effective date
2018-07-12
Treasury docket
TD 9834
Abstract
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.