Treasury, IRS Finalize Regs to Block ‘Killer B’ Transactions (2)

The Treasury Department and the IRS issued final regulations to try to rein in “Killer B” triangular reorganizations involving foreign corporations, which the government says companies have used to avoid taxes.

The final rules (TD 10004, RIN 1545-BM19), issued Wednesday, are aimed at blocking a kind of transaction that the government has said US companies could use to bring foreign income back to the US without paying taxes on it, or to execute corporate tax “inversions” in which US companies shift their headquarters to lower-taxed countries.

Triangular reorganizations are transactions in which a subsidiary buys stock in its ...