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Internal Revenue Service › Outbound Transactions

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
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

Sheppard Mullin Richter & Hampton LLP

Congress Passes Final Tax Reform Bill: U.S. Tax Reform: The Current State of Play

Sheppard Mullin Richter & Hampton LLP on

With the affirmative vote in the House today, both Houses of Congress have now passed a final version of the Tax Cuts and Jobs Act, clearing the legislation for President Trump’s signature. President Trump is widely expected...more

Alston & Bird

New Regulations on F Reorganizations

Alston & Bird on

In late September, the IRS issued final regulations describing six requirements for a transaction or series of transactions to qualify as a reorganization under Section 368(a)(1)(F) (an “F reorganization”). The IRS...more

Eversheds Sutherland (US) LLP

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

Eversheds Sutherland (US) LLP on

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"

Skadden, Arps, Slate, Meagher & Flom LLP on

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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