On 12 July 2018, TD 9834 was published in the U.S. Federal Register, which contains the final anti-inversion regulations addressing transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code and certain post-inversion tax avoidance transactions. The regulations finalize the regulations first issued in April 2016. The final regulations are largely in line with the initial regulations, although some clarifications/modifications have been made.
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