IRS continues to crack down on corporate inversions

Description

Abstract: IRS Notice 2015-79 represents just the latest attack on corporate inversion transactions. According to the Notice, the IRS intends to issue regulations designed to make it more difficult for companies in the United States to invert, and to limit the tax benefits of this strategy. This article discusses the history of IRC Section 7874, the 2004 regulation designed to thwart the use of corporate inversions for tax avoidance. It also makes it clear that the new regulations make needed changes to help achieve the intent of Sec. 7874.