The Treasury Department and the IRS released Notice 2014 52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of certain post-expatriation transactions and also narrow exceptions to the expatriation rules of Section 7874. The post-expatriation transactions that are the subject of the Notice are transactions in which previously untaxed earnings of the acquired U.S. corporation might otherwise escape U.S. tax. The Notice states that these Treasury regulations generally will apply to transactions completed on or after September 22, 2014 (i.e., no grandfathering).
View full memo, Treasury and IRS Issue Inversion Notice