applicable period

(2) The applicable period means, with respect to an inversion transaction, the period described in section 7874(d)(1). However, see also 1.78742(b)(13) in the case of a subsequent acquisition (or a similar acquisition under the principles of 1.78742(c)(4)(i)) that is an inversion transaction.


26 CFR § 1.7874-12

Scoping language

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