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- 1.Corporate Expatriation Transactions: IRS Announces Intent to Issue Further Guidance Under Section 7874
- Publish Date
- 08 Oct 2009
- Organisation
- Sullivan & Cromwell LLP
- Summary
On September 17, 2009, the IRS issued Notice 2009-78 (the "Notice"), stating that the IRS and Treasury Department will issue regulations (the "Regulations"), to be effective immediately, that will expand the "anti-inversion" rules of Section 7874. The Regulations will provide new rules for stock of an acquiring foreign corporation or partnership interests in an acquiring publicly traded foreign partnership that are issued for cash, marketable securities or otherwise with a purpose to avoid Section 7874.
- Jurisdictions
-
- United States
- Sectors
-
- Company
- Banking & Finance
- Tax
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