Earlier this year, the IRS released T.D. 9761, which included final and temporary regulations under Code §7874. The regulations contain new rules addressing inversions and certain post-inversion tax avoidance transactions.
Today we have released over 50 situational charts that illustrate all of the examples embedded in the Code §7874 regulations. Specifically, the situational charts include the examples found in the following regulation sections:
- Treas. Reg. §1.7874–1 Disregard of affiliate-owned stock
- Treas. Reg. §1.7874–2 & –2T Surrogate foreign corporation
- Treas. Reg. §1.7874–4T Disregard of certain stock related to the acquisition
- Treas. Reg. §1.7874-5T Effect of certain transfers of stock related to the acquisition
- Treas. Reg. §1.7874–6T Stock transferred by members of the EAG
- Treas. Reg. §1.7874–7T Disregard of certain stock attributable to passive assets
- Treas. Reg. §1.7874–8T Disregard of certain stock attributable to multiple domestic entity acquisitions
- Treas. Reg. §1.7874–9T Disregard of certain stock in third-country transactions
- Treas. Reg. §1.7874–11T Rules regarding inversion gain
The charts are available at http://www.andrewmitchel.com/topic.php#7874, where you can find hundreds of other situational charts.