IRS Could Get Tough On Inversions With 'Killer B' Regs
Law360, New York (May 9, 2014, 5:20 PM EDT) -- In a push to dampen tax-free repatriation transactions, the Internal Revenue Service recently said it will tighten its anti-abuse rules for triangular reorganizations involving at least one foreign company, clamping down on so-called Killer B transactions and likely shutting down a tax inversion structure in the process.
Killer B transactions involve property or stock exchanges between a parent, subsidiary and target company, and they raise the possibility of tax avoidance because foreign entities are involved. In 2011, the IRS thought it solved those tax avoidance problems when it issued final regulations, but taxpayers found loopholes and read the agency's anti-abuse rules...
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