View Rule

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.