Earlier this month the Treasury & IRS issued final regulations dealing with “inversions” – the generic term for a domestic corporation’s adoption of a foreign-parented corporate structure – and certain post-inversion restructurings. The final regulations primarily follow the roadmap laid out in the temporary regulations issued in April 2016, with several changes & clarifications.
This 29-page KPMG memo provides a detailed review of the final regulations & highlights differences between the temporary & final regs. I’d include an excerpt – but I don’t understand enough of this to provide a coherent intro, and I can’t even fake it like I usually do!
– John Jenkins