Notice Says IRS to Issue New Rules on Corporate Inversions

The Tax Management Transfer Pricing Report ™ provides news and analysis on U.S. and international governments’ tax policies regarding intercompany transfer pricing.

IRS issues Notice 2009-78 stating its intent to issue regulations to incorporate rules that will identify certain stock of a foreign corporation that is disregarded for determining ownership of the foreign corporation under §7874. IRS says the regulations will address certain transactions, including those intended to avoid the application of §7874 that involve a transfer of cash or certain other assets to the foreign corporation in a transaction related to an acquisition.