On 29 September 2017, the U.S. District Court in Austin, Texas issued its decision that the temporary regulations (T.D. 9761) (the Rule) issued by the IRS in April 2016 to deter corporate inversions was not lawfully issued. The Rule essentially allows the IRS to disregard foreign parent stock attributable to recent inversions or acquisitions of U.S. companies in the previous three years so that inverting companies are less likely to be able to meet the continuity of ownership thresholds for a…