IRS Open to Releasing Rules on Inversion Transactions

The IRS is open to issuing rulings on the application of inversion rules to acquisitions by a foreign corporation, an agency official said Thursday.

An inversion is when a US multinational company is acquired by a smaller foreign company and establishes residency in that country. Final rules released in 2018 under Section 7874 made inversions less attractive for companies, slowing inversion activity.

• There are some deals in which the Section 7874 rules apply unexpectedly for companies. While there is no active guidance project on that section, Laura Williams, branch chief at the Office of ...