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TREAS/IRS | RIN: 1545-BM45 | Publication ID: Spring 2015 |
Title: Post-Inversion Acquisitions to Avoid Section 956 and Transactions to De-Control or Significantly Dilute CFCs | |
Abstract:
These regulations will incorporate certain rules described in sections 3.01 and 3.02 of Notice 2014-52, which applies to certain inversion transactions. These regulations will treat stock and obligations of certain foreign affiliates of an expatriated entity as United States property within the meaning of section 959(c) (1). These regulations will also recharacterize certain foreign affiliates of an expatriated entity as United States property within the meaning of section 959(c)(1). These regulations will also recharacterize certain post-inversion transactions that would otherwise terminate the controlled foreign corporation (CFC) status of foreign subsidiaries and/or substantially dilute the interests of United States shareholders |
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Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Proposed Rule Stage |
Major: Undetermined | Unfunded Mandates: No |
CFR Citation: 26 CFR 1.956-2 26 CFR 1.954-2 | |
Legal Authority: 26 U.S.C. 0956(e) 26 U.S.C. 7701(l) 26 U.S.C. 0964(c)(6)(A) |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-135734-14 Drafting attorney: Rose E. Jenkins (202) 317-6934 Reviewing attorney: Barbara Rasch (202) 317-6934 Treasury attorney: Brenda Zent CC:INTL | |
Regulatory Flexibility Analysis Required: Undetermined | Government Levels Affected: Undetermined |
Federalism: Undetermined | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Rose E. Jenkins Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-6934 Fax:855 589-8671 Email: rose.e.jenkins@irscounsel.treas.gov |