U.S. IRS Publishes Practice Units on Corporate Inversions and Failure to File Return of Transfer of Property to Foreign Corporation

The U.S. IRS has recently published two international practice units, including:

• Corporate Inversions - Overview of Major Issues, which covers the application of IRC 7874 and the treatment of a new foreign parent corporation of the domestic target as a surrogate foreign corporation, and the related tests; and
• Failure to File the Form 926 – Return by a U.S. Transferor of Property to a Foreign Corporation – Monetary Penalty, which covers the determination process for the penalty for failing …