Firm Tells IRS to Scrap ‘Outdated’ Inbound Transactions Rules

June 5, 2026, 8:29 PM UTC

Current US rules governing the tax treatment of inbound corporate transactions are outdated and can block foreign companies that would like to become American, law firm Sullivan & Cromwell told the IRS Friday, urging removal of the regulations entirely.

Changes Republicans made in their 2017 tax law, like cutting the corporate rate to 21%, made the US an attractive place to do business, the firm said in a letter to the agency. These changes, in addition to the strength of American capital markets, have resulted in a number of companies domesticating in the US, it said.

“Many more wish to ...

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