Section 7874 Inversion Rules Out Soon, Treasury's Rolfes Says

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The Treasury Department will issue guidance on inversions involving foreign corporations under tax code Section 7874 “any day now,” among a host of other international guidance priorities headlined by the Foreign Account Tax Compliance Act, Treasury International Tax Counsel Danielle Rolfes said.
Rolfes said Jan. 14 that the eagerly awaited Section 7874 guidance would put Notice 2009-78 into regulations. That notice described when the Internal Revenue Service would identify certain stock of a foreign corporation that is disregarded for determining ownership of the foreign corporation (179 DTR G-2, 9/18/09)
“It's the very next thing to come out,” Rolfes said at a luncheon sponsored by Bloomberg BNA Tax & Accounting and hosted by Buchanan Ingersoll & Rooney PC. “It will be any day now,” she said.

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