Treasury has issued new proposed and temporary inversion regulations.
In addition, the regulations contain the following rules (as set forth in the preamble):
(i) rules for identifying a foreign acquiring corporation when a domestic entity acquisition involves multiple steps;
(ii) rules that disregard stock of the foreign acquiring corporation that is attributable to certain prior domestic entity acquisitions;
(iii) rules that require a controlled foreign corporation (CFC) to recognize all realized gain upon certain transfers of assets described in section 351 that shift the ownership of those assets to a related foreign person that is not a CFC; and
(iv) rules clarifying the definition of group income for purposes of the substantial business activities test.
And a Chicago Tribune article discussing the new regulations.