Corporate Inversions: IRS Guidance Tightens the Rules Awaiting Tax Reform


Bloomberg Tax's Helena Klumpp writes that while Congress ponders corporate tax reform, corporate inversion transactions have provided self-help opportunities for U.S. companies. She reviews the IRS's new anti-inversion rules (T.D. 9761) that target such transactions, as well as post-inversion transactions that facilitated the removal of U.S. and offshore income from the U.S. tax net.