global Tax New IRS Rules Regarding Corporate Inversions November 21, 2014 Disclaimer This post was published more than two years ago, and some information may now be out of date. We want to help you make the best decisions possible—please connect with your advisor or check out our latest resources for the most current guidance. The IRS attempts to curb the use of corporate inversion used by U.S. corporations and institutes a number of new provisions and regulations. U.S. corporations have availed themselves of something called “corporate inversions” in recent years, which is the process by which they change their country of residence (typically through becoming a subsidiary of a foreign parent corporation) in order to face lower tax rates and avoid U.S. tax on foreign source income altogether. As a reaction to this, the IRS has issued regulations and a series of measures to discourage this unearned tax break.The new regulations will…Tighten ownership requirementsLimit access to earnings by preventingHopscotch loansDecontrollingTax-free repatriationsFor more information, read our article, “IRS makes move against corporate inversions”.
