Bill > S4275

This bill, the Stop Corporate Inversions Act of 2024, amends the Internal Revenue Code to modify the rules relating to inverted corporations. The key provisions include: 1. Treating a foreign corporation as a domestic corporation if it would be considered a surrogate foreign corporation (where more than 80% of the stock is held by former shareholders of the domestic corporation) or if it is an "inverted domestic corporation" (where a foreign corporation acquires substantially all the assets or a trade/business of a U.S. corporation or partnership, and after the acquisition, more than 50% of the stock is held by former shareholders/partners, or the management and control of the expanded affiliated group primarily occurs in the U.S. and the group has significant domestic business activities). 2. Providing an exception where the expanded affiliated group has substantial business activities in the foreign country where the entity is created or organized. 3. Directing the Secretary of the Treasury to issue regulations for determining when the management and control of an expanded affiliated group is primarily in the U.S., and defining when an expanded affiliated group has significant domestic business activities. 4. Applying these provisions to taxable years ending after May 8, 2014.