### Question
How does Procedure and Administration define inversion gain?


### Answer
Under *26 U.S.C. § 7874*, **inversion gain** is defined as:

> the income or gain recognized by reason of the transfer during the applicable period of stock or other properties by an expatriated entity, and any income received or accrued during the applicable period by reason of a license of any property by an expatriated entity—


(A) as part of the acquisition described in subsection (a)(2)(B)(i), or


(B) after such acquisition if the transfer or license is to a foreign related person

#### Citation:
  - *26 U.S.C. § 7874*
  - Heading: **Subtitle F-Procedure and Administration > CHAPTER 80-GENERAL RULES > Subchapter C-Provisions Affecting More Than One Subtitle**

