Corrections Made to U.S. Regulations on Guidance for Determining Stock Ownership

On 7 September 2017, corrections to the U.S. IRS final regulations on guidance for determining stock ownership (TD 9812) were published in the Federal Register. The regulations are in relation to the anti-inversion rule that allows the IRS to disregard foreign parent stock attributable to recent inversions or acquisitions of U.S. companies in the previous three years ({News-2017-01-19/A/4-previous coverage}). The corrections clarify certain aspects of the regulations that may prove to be mis…