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Inversion Regulations: The Illusory "Safe Harbor"

[On June 7, 2012], Treasury issued temporary and proposed ( T.D. 9592 ) and final ( T.D. 9591 ) regulations under IRC Section 7874 to "provide more certainty in applying IRC § 7874 " and to "improve the administrability" of the substantial business activities exception (see Preamble...