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... Read more →