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U.S. Issues New Regulations on Inversions and Earnings Stripping

06 April 2016

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Approved Changes

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United States

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 disregard foreign parent stock attributable to recent inversions or acquisitions of U.S. companies in the previous three years. This is meant to limit inversions by preventing foreign companies that acquire multiple U.S. companies in stock-based transactions from using the resulting increase in size to avoid...