Bill > HR2976

This bill amends the Internal Revenue Code to modify the rules relating to inverted corporations. The key provisions are: 1. A foreign corporation will be treated as a domestic corporation for tax purposes if it would be considered a surrogate foreign corporation (where more than 80% of the stock is held by former shareholders of the acquired domestic corporation) or if it is an "inverted domestic corporation" (where more than 50% of the stock is held by former shareholders/partners of a domestic corporation/partnership that was acquired, and the management and control of the expanded affiliated group primarily occurs in the U.S. with significant domestic business activities). 2. The bill provides exceptions for foreign corporations with substantial business activities in the foreign country where they are organized. 3. The bill directs the Secretary of the Treasury to issue regulations for determining when the management and control of an expanded affiliated group is primarily within the U.S. 4. The bill also makes conforming amendments to existing provisions in the tax code related to inverted corporations.