News & Analysis as of

Foreign Corporations Outbound Transactions

Wiley Rein LLP

Wiley's 10 Key Trade Developments: Outbound Investments and CFIUS Review

Wiley Rein LLP on

Outbound foreign investments by U.S.-based companies in sensitive technologies may impact foreign companies from operating in the U.S. or doing business with U.S. companies. Mandatory filing requirements and high-profile...more

Freeman Law

Gain Recognition Agreements and Outbound Stock Transfers

Freeman Law on

GRAs and Section 367(a)(1) Outbound Stock Transfer Rules Overview - Introduction to Section 367(a)(1), Outbound Stock Transfers, and Gain Recognition Agreements - Section 367(a) of the Internal Revenue Code (the “Code”)...more

Alston & Bird

Partnership Abuse of Entity Rule Invoked in Section 367(d) Outbound IP Transaction

Alston & Bird on

Our International Tax Group explores a recent, heavily redacted Chief Counsel Advice applying the partnership abuse of entity rule to a Section 367(d) outbound IP transaction....more

Eversheds Sutherland (US) LLP

Proposed Regulations Dramatically Change U.S. Federal Tax Treatment of Outbound Transfers of Intangible Property

On September 16, 2015, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published proposed regulations under section 367 and proposed and temporary regulations under section 482 that together would...more

Skadden, Arps, Slate, Meagher & Flom LLP

"New Regulations Address Outbound Transfers and Transfer Pricing"

On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under Section 367 of the Internal Revenue Code (the Code) of certain transfers by...more

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