The proposed regulations include a taxpayer-favorable rule that would remove a significant disincentive to repatriating previously "outbounded IP."Taxpayers evaluating whether to repatriate IP subject to IRC Section 367(d) are encouraged to consider whether the proposed regulations would present a repatriation opportunity that simplifies their operating model and aligns IP ownership with the functions and employees associated with the IP. In proposed regulations (REG-124064-19; Proposed Regulations) released 2 May 2023, the United States (US) Department of Treasury (Treasury) and the Internal Revenue Service (IRS) would apply new rules to "repatriations" of intangible property (IP) subject to IRC Section 367(d). In certain...