1545-BM45 201410 The Regulatory Plan and the Unified Agenda of Federal Regulatory and Deregulatory Actions 1545 Internal Revenue Service IRS 1500 Department of the Treasury TREAS Post-Inversion Acquisitions to Avoid Section 956 and Transactions to De-Control or Significantly Dilute CFCs

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

]]> Substantive, Nonsignificant First Time Published in The Unified Agenda Proposed Rule Stage Undetermined No 26 CFR 1.956-2 26 CFR 1.954-2 26 USC 0956(e) 26 USC 7701(l) 26 USC 0964(c)(6)(A) No NPRM 12/00/2014 REG-135734-14 Drafting attorney: Rose E. Jenkins (202) 317-6934 Reviewing attorney: Barbara Rasch (202) 317-6934 Treasury attorney: Brenda Zent CC:INTL Undetermined Undetermined Undetermined No No Rose Jenkins E. Attorney-Advisor 1545 Internal Revenue Service IRS 202 317-6934 855 589-8671 rose.e.jenkins@irscounsel.treas.gov 1111 Constitution Avenue NW., Washington DC 20224