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U.S. Treasury › Repatriation

Proskauer - Tax Talks

Proposed Regulations Issued for Repatriations of Intangible Property under Section 367(d)

Proskauer - Tax Talks on

On May 2, 2023, the Department of the Treasury and Internal Revenue Service (“IRS”) issued proposed Treasury Regulations (REG-124064-19) that would, in certain cases, terminate the application of Section 367(d) when...more

Morgan Lewis

IRS, Treasury Issue Guidance on Section 965 Deemed Repatriation Rules, Signal Important Form 5471 Exception

Morgan Lewis on

Notice 2018-13 details the government’s intent to issue regulations addressing additional Section 965 computational issues. The new regulations will clarify, among other things, that US shareholders will be permitted to elect...more

BakerHostetler

U.S. Treasury Department Takes Action to Slow (But Not Stop) Corporate Inversions: A Summary for Executives

BakerHostetler on

What is an inversion? An inversion is a transaction that results in an existing U.S. company becoming a foreign company or becoming a subsidiary of a foreign parent. Historically, inversions involved U.S. companies...more

Bilzin Sumberg

“Return of Basis” Repatriation Strategy Tested in Tax Court

Bilzin Sumberg on

U.S. multinationals literally have trillions of dollars of untaxed earnings purportedly “trapped” offshore because of the associated high U.S. corporate income taxes that would be incurred if these earnings were repatriated...more

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