The US Anti-Inversion Legislation and Regulations
Bulletin for International Taxation, Vol. 60, p. 377, Aug/Sept 2006
6 Pages Posted: 12 Feb 2010
Date Written: August 31, 2006
Abstract
This article discusses section 7874 of the Internal Revenue Code and regulations issued thereunder by the IRS and Treasury in 2005 and 2006. The statute is aimed at discouraging corporate inversions and potential US tax avoidance that can result from an inversion transaction. The regulations deal with a number of issues arising from the statutory language, and include anti-avoidance measures thought to be authorized by the broad regulatory authority granted to the IRS and Treasury by Congress to issue regulations to prevent avoidance of the purposes of the statute.
Keywords: United States, tax, inversions, 7874
JEL Classification: K34
Suggested Citation: Suggested Citation