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final regulations

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

July 9, 2015 By Heather Ripley

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

Filed Under: International - Corporate Tax Planning, International Tax Advisory, Mergers and Acquisitions - International Tagged With: Corporate Inversions, Corporate Tax Planning, final regulations, inversions, Section 7874

Few Changes in Final Rules on Foreign Tax Credit Splitters

February 17, 2015 By Heather Ripley

On February 9, 2015, the U.S. Treasury released final regulations on foreign tax credit (FTC) splitting arrangements (the “2015 Regulations”). The final rules, released the same day that the 2012 temporary and proposed regulations were set to expire, offer some definitional and other clarifications and add useful illustrations. But for the most part, the 2015 Regulations adopt the prior proposed and temporary regulations, including the exclusive list of FTC splitter arrangements. Notably, the final rules fail to address several “mechanical issues” (i.e., issues concerning the tracking [...]Read more

Filed Under: International - Corporate Tax Planning, International - Inbound, International - Outbound, International Tax Advisory Tagged With: final regulations, foreign tax credit, foreign tax credit splitter, FTC, hybrid instrument, loss sharing, reverse hybrid, section 909

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