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Practitioners should not expect section 7874 anti-inversion regulations that provide guidance on substantial business activities to be finalized within the current business plan year, which ends June 30, but rather can expect finalization in the next business plan year, an IRS official said December 12.
"They are, of course, on our to-do list. . . . Ahead of this project and what we have been focusing our energies on is a different 7874 project that focuses on the ownership continuity test," Daniel McCall, special counsel, IRS Office of Associate Chief Counsel (International), said at the annual Institute on Current Issues in International Taxation, cosponsored by George Washington University Law School and the IRS.
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