Tag Archives: Corporate Inversions

Final Anti-Inversion Regulations Keep Strict 25 Percent Tests for Substantial Business Activities

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In June, the IRS and U.S. Treasury released final regulations under the anti-inversion provisions of Section 7874 (T.D. 9720). The final rules, effective for acquisitions completed on or after June 3, 2015, include a few changes from the regulations proposed in 2012. Most notably, the final rules retain the 25 percent bright-line tests for whether an expanded affiliated group (EAG) has “substantial business activities” in a foreign country for the purpose of determining whether the foreign parent of an inverted corporation will be treated as a “surrogate foreign corporation.” The controversial [...]Read more

International Tax ADVISORY: Land of the Freely Inverting Corporation

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Alston & Bird’s International Tax Group reviews congressional proposals to curb corporate inversions amid debate over the need for comprehensive tax reform.  The advisory is provided on the Alston & Bird website: http://www.alston.com/advisories/int-tax-aug-2014/