IRS Proposal on Corporate Inversions Welcomed for De Minimis Provision

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The Internal Revenue Service unveiled long-awaited rules on corporate inversions under Section 7874 that may be broader in some respects than 2009 guidance, yet contain a welcome de minimis rule, practitioners told Bloomberg BNA.
The Jan. 16 proposed (REG-121534-12) and final and temporary rules (T.D. 9654) are the latest development in the government's effort to implement Section 7874, enacted by Congress to prevent transactions in which companies “invert” to avoid taxes.
The rules incorporate the previous guidance of Notice 2009-78 (179 DTR G-2, 9/18/09).

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