On 12 July 2018, TD 9834 was published in the U.S. Federal Register, which contains the final anti-inversion regulations addressing transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code and certain post-inversion tax avoidance transactions. The regulations finalize the regulations first issued in April 2016. The final regulations are largely in line with the initial regulations, although some clarifications/modifications have been made. Section 7874 Under section 7874, a new foreign parent of a domestic U.S. target will be considered as a surrogate foreign corporation if three tests are met: The foreign...