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Expert Analysis

Inversion Rules Could Apply To Inbound Structures

Law360, New York (January 27, 2015, 10:30 AM EST) -- In Private Letter Ruling 201432002, the IRS ruled that a foreign-to-foreign "F" reorganization did not implicate the Section 7874 anti-inversion rules. As a result, a foreign corporation (that was 100 percent foreign-owned) was not deemed to be a U.S. corporation for U.S. federal income tax purposes, despite the fact that it was deemed to transfer substantially all of the properties of a domestic subsidiary corporation to a foreign corporation that had no substantial business activities in its country of incorporation. The specific exception relied on by the IRS to reach this conclusion was the "expanded affiliated group rule."...

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