What are the anti-inversion rules under IRC 7874 and how do they affect foreign-owned structures?
I've been reading about corporate inversions — companies moving their tax domicile overseas to reduce U.S. taxes. We are a foreign company considering acquiring a U.S. target, and our advisors warned us about the Section 7874 inversion rules. Could our acquisition inadvertently make our foreign parent treated as a U.S. corporation? What ownership thresholds trigger these rules?
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