On 4 April 2016, the U.S. IRS issued final and temporary regulations (T.D. 9761) and proposed regulations (REG-135734-14). The regulations include previous rules on inversions included in Notice 2015-79 and Notice 2014-52 ({News-2015-11-24/A/2- previous coverage}) and new rules targeting inversions and earnings stripping.

New Anti-Inversion Rules

The new rules on inversions allow the IRS to…