U.S. IRS Publishes Final and Temporary Regulations: Guidance for Determining Stock Ownership; Rules Regarding Inversions and Related Transactions

On 18 January 2017, U.S. IRS final and temporary regulations (TD 9812) were published in the Federal Register. The final and temporary regulations concern the determination of stock ownership and rules regarding inversions and related transactions. The regulations adopt and remove prior temporary regulations published in 2014 (TD 9644) and modified in 2016 (TD 9761) concerning the anti-inversion rule that allows the IRS to disregard foreign parent stock attributable to recent inversions or ac…