IRS Revises "Anti-Inversion" Regulations Under Code Section 7874

more+
less-

On June 9, 2009, the IRS issued new final and temporary regulations (T.D. 9453) under the “anti-inversion” rules of Section 7874 of Internal Revenue Code of 1986, as amended (the “Code”). The new regulations (the “2009 Regulations”) address the classification of a foreign corporation as a “surrogate foreign corporation” subject to adverse U.S. tax treatment, including potential U.S. taxation of the foreign corporation’s worldwide income. The 2009 Regulations replace temporary regulations published in June 2006 (the “2006 Regulations”), and in many respects are more restrictive than the 2006 Regulations. The 2009 Regulations generally apply to acquisitions completed on or after June 9, 2009.

Please see full update for more information.

LOADING PDF: If there are any problems, click here to download the file.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Morrison & Foerster LLP | Attorney Advertising

Written by:

more+
less-

Morrison & Foerster LLP on:

JD Supra Readers' Choice 2016 Awards
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×
Loading...
×
×