OrbitaxFinal regulations issued on surrogate foreign corporations in offshore inversion transactions
|Approved Changes|United States
The US Treasury Department and the Internal Revenue Service (IRS) have issued final regulations (TD 9591) with guidance on offshore inversion transactions. The regulations were issued under section 7874 of the US Internal Revenue Code (IRC), which applies to US-expatriated entities and their surrogate foreign corporations.
Offshore inversion transactions refer to transaction…
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