The U.S. IRS and Treasury have issued proposed regulations, Section 367(d) Rules for Certain Repatriations of Intangible Property, which were published in the Federal Register on 3 May 2023. Under Section 367(d), it is essentially provided that when a U.S. person transfers intangible property to a foreign corporation in certain cases, the U.S. person is considered to receive deemed income in respect of the intangible property. Specifically, the U.S. transferor is treated as receiving amounts that reasonably reflect the amounts that would have been received annually in the form of such payments over the useful life of the intangible property...