On 3 June 2015, the U.S. IRS and U.S. Treasury issued Final Regulations T.D. 9720 concerning when an expanded affiliated group (EAG) will be considered to have substantial business activities in a foreign country. As included in the 2012 temporary regulations, the final regulations maintain that an EAG will be considered to have substantial business activities in the relevant foreign country only if at least 25% of its group employees, group assets, and group income are located or derived in the relevant foreign country. The substantial business activities test is used in regard to corporate inversions, where there is a...