Inversions and Related Transactions - Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition‪)‬

The Law Library presents the complete text of the Inversions and Related Transactions - Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition).
Updated as of May 29, 2018

This document contains final regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation. These regulations also provide guidance on the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of a domestic corporation or of a trade or business of a domestic partnership. These regulations affect certain domestic corporations and partnerships (and certain parties related thereto) and foreign corporations that acquire substantially all of the properties of such domestic corporations or of the trades or businesses of such domestic partnerships. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on Rules Regarding Inversions and Related Transactions in the Proposed Rules section of this issue of the Federal Register.

This ebook contains:
- The complete text of the Inversions and Related Transactions - Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition)
- A dynamic table of content linking to each section
- A table of contents in introduction presenting a general overview of the structure