Initial analysis of final regulations, “inversions” | KPMG | GLOBAL
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KPMG report: Initial analysis of final regulations addressing “inversions”

Initial analysis of final regulations, “inversions”

The U.S. Treasury Department and IRS on July 11, 2018, released for publication in the Federal Register final regulations (T.D. 9834) addressing “inversions”—the generic term for a domestic corporation’s adoption of a foreign-parented corporate structure—and certain post-inversion restructuring transactions.

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The final regulations [PDF 376 KB] as published in the Federal Register on July 12, 2018, primarily adopt temporary regulations issued on April 4, 2016 (and scheduled to expire on April 4, 2019) with several changes and clarifications.  

 

Read a July 2018 report [PDF 521 KB] prepared by KPMG LLP providing an initial analysis of the final regulations

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