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 transactions whereby the US parent corporation of a multinational group is replaced by a foreign parent corporation (i.e. a surrogate foreign corporation) without a significant change in the ultimate ownership of the group, or similar transactions in which a trade or business of a US domestic partnership is transferred...