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 rely on these rules for intangible property repatriations that occurred before their publication. On October 9, 2024, the United States (US) Department of Treasury (Treasury) and the Internal Revenue Service (IRS) released final regulations under IRC Section 367(d) (T.D. 9994; Final Regulations) on certain repatriations of intangible property (IP). The...