CCH Tax Day Report The IRS has issued final inversions regulations under Code Sec. 7874 that disregard certain stock of the foreign acquiring corporation in calculating the stock ownership percentage for purposes of determining if the corporation is a surrogate foreign corporation. The regulations also provide guidance on the effect of transfers of the foreign […]
The post Final Inversions Regulations Provide Guidance on Calculating the Ownership Percentage and Subsequent Transfers of Foreign Acquiring Corporation Stock (T.D. 9812, NPRM REG-135734-14) appeared first on Tax & Accounting Blog.