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United States | Final IRC Section 367(d) regulations open door to intangible property repatriation for US multinationals

|Tax Alerts, National/Federal Taxation, G ...|United States
United States

  • Closely mirroring guidance introduced by proposed regulations in May 2023, the final regulations establish that the continued application of IRC Section 367(d) terminates when a foreign corporation transfers previously outbounded intangible property to a "qualified domestic person" and certain reporting requirements are satisfied.
  • The final regulations apply prospectively only, and taxpayers cannot…

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