Corporate Inversion Transactions

The Internal Revenue Service and the Treasury Department recently published new regulations that address corporate inversion transactions. Most notably, these new regulations:

  • expand the application of the “associated obligations” rule and exclude intercompany obligations from “nonqualified property” that gives rise to disqualified stock,

  • retain the distinction between stock and asset reorganizations,

  • leave undisturbed pre-IPO buyout transactions and

  • modify certain de minimis exceptions.