Date: 2018-07-12
Links to Federal Register: HTML, PDF
(Proposed Regulation: REG-135734-14 / TD 9761 HTML, PDF)
Document Number: 2018-14693, RIN: 1545-BO20
Action: Final regulations, temporary regulations, and removal of temporary regulations.
Abstract: This document contains final regulations that address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain post- inversion tax avoidance transactions. These regulations affect certain domestic corporations and domestic partnerships whose assets are directly or indirectly acquired by a foreign corporation and certain persons related to such domestic corporations and domestic partnerships. This document finalizes proposed regulations, and removes temporary regulations, published on April 8, 2016.
| Notable phrases | Frequency |
|---|---|
| domestic entity acquisition(s) | 185 |
| foreign acquiring corporation | 141 |
| ownership percentage | 95 |
| expatriated foreign subsidiary | 93 |
| disregarded specified stock | 53 |
| controlled foreign corporation(s) | 53 |
| denominator of the ownership fraction | 50 |
| specified related person | 48 |
| expanded affiliated group | 41 |
| fair market value | 40 |
| former domestic entity shareholder | 36 |
| group nonqualified property | 34 |
| by reason of | 30 |
| deemed issued stock | 29 |
| foreign group nonqualified property | 29 |
| fair market value of the stock | 13 |
| total voting power and value of the stock | 10 |
| substantially all of the properties | 9 |
| related to the domestic entity | 9 |
| stock is excluded from the denominator | 8 |
| five percent former domestic entity shareholder | 6 |
| Reg. Cites | Frequency |
|---|---|
| 1.7874-1 | 27 |
| 1.7874-12 | 22 |
| 1.7874-4(b) | 11 |
| 1.7874-8(b) | 9 |
| 1.7874-6 | 8 |
| 1.7874-10 | 8 |
| 1.367(b)-4 | 7 |
| 1.7701(l)-4 | 7 |
| 1.7874-12T | 7 |
| 1.7874-7 | 7 |
| 1.7874-8 | 7 |
| 1.7874-4 | 6 |
| 1.304-7 | 6 |
| 1.7874-9(b) | 6 |
| 1.7874-7T | 6 |
| 1.7874-10(b) | 6 |
| 1.7874-9T | 6 |
| 1.7874-10T | 6 |
| 1.7874-1(d)(1) | 5 |
| 1.7874-4(h)(2) | 5 |
| Sec. Cites | Frequency |
|---|---|
| 958(a) | 35 |
| 7874(a)(2)(B)(ii) | 34 |
| 7874 | 33 |
| 7874(c)(2)(A) | 27 |
| 361(c)(1) | 15 |
| 7874(c)(4) | 11 |
| 1248 | 10 |
| 304(b)(5)(B) | 8 |
| 956 | 8 |
| 304(c)(3)(B) | 7 |
| 318(a) | 7 |
| 351 | 7 |
| 7874(a)(2)(B)(i) | 6 |
| 355 | 6 |
| 368(a)(1)(D) | 6 |
| 956(a) | 5 |
| 318(a)(3) | 5 |
| 267(b) | 4 |
| 367(b) | 4 |
Statistics
Number of pages: 38, words: 43,058, sentences: 1,559
Average words per sentence: 27