pre-inversion year

(B)For purposes of subparagraph (A), the term “pre-inversion year” means any taxable year if— (i)any portion of the applicable period is included in such taxable year, and (ii)such year ends before the taxable year in which the acquisition described in subsection (a)(2)(B)(i) is completed. (f)Nothing in section 894 or 7852(d) or in any other provision of law shall be construed as permitting an exemption, by reason of any treaty obligation of the United States heretofore or hereafter entered into, from the provisions of this section. (g)The Secretary shall provide such regulations as are necessary to carry out this section, including regulations providing for such adjustments to the application of this section as are necessary to prevent the avoidance of the purposes of this section, including the avoidance of such purposes through—

Source

26 USC § 7874(e)(4)(B)


Scoping language

For purposes of subparagraph
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