IRS Announces Additional Revisions to “Anti-Inversion” Regulations Under Code Section 7874

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On September 17, 2009, the Internal Revenue Service (“IRS”) issued Notice 2009-78 (“Notice”) announcing its intention to issue additional regulations under the “anti-inversion” rules of Section 7874 of the Internal Revenue Code of 1986, as amended (“Code”). The most recent previous guidance by the IRS under Code Section 7874 was final and temporary regulations issued in June, 2009.[1] The additional new regulations will incorporate the rules described in the Notice that will identify certain stock of a foreign corporation that is disregarded for determining ownership of the foreign corporation in applying the anti-inversion rules.

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