22 June 2012
Report from Wooje Choi, IBFD North America
The US Treasury Department and the Internal Revenue Service (IRS) have issued temporary regulations (TD 9592) with guidance on offshore inversion transactions. The regulations were issued under section 7874 of the US Internal Revenue Code (IRC), which applies to US-expatriated entities and their surrogate foreign corporations.
Offshore inversion transactions refer to transactions whereby t…