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Intangible Property Foreign Corporations

McDermott Will & Emery

IRS Releases Proposed Regulations Addressing Repatriations of Intangible Property

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BACKGROUND: SECTION 367(D) Section 367(d) generally addresses outbound transfers of intangible property to a foreign corporation. It treats a US transferor that transfers intangible property subject to Section 367(d) as...more

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

McDermott Will & Emery

IRS Releases Memorandum Regarding Advance Payments of Section 367(d) Inclusions

McDermott Will & Emery on

On September 23, 2022, the Internal Revenue Service (IRS) released a memorandum (AM 2022-003) concluding that taxpayers cannot make advance payments of section 367(d) inclusions except in the limited situation in which the US...more

Freeman Law

The Source of Income from the Sale of Personal Property

Freeman Law on

The Source of Income from the Sale of Personal Property Generally, income from the sale of personal property is “sourced” to the residence of the seller. If the seller is a U.S. tax resident the source of the income is deemed...more

Freeman Law

The Tax Court in Brief – TBL Licensing LLC v. Commissioner

Freeman Law on

Tax Litigation: The Week of February 7 – February 11, 2022 Williams v. Commissioner Sloane v. Commissioner TBL Licensing LLC v. Comm’r, Corrected 158 T.C. 1 | February 8, 2022 | Filed January 31, 2022 | Halpern, J. | Dkt. No....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

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 2 - An Overview of the Tax Act's Effects on Various...

Holland & Knight LLP on

• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - October 2015

McDermott Will & Emery on

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...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

Morrison & Foerster LLP

IRS Issues Notice Announcing Intention to Require Gain Recognition on Certain Transfers of Property to Partnerships with Related...

I. Overview - On August 6, 2015, the Internal Revenue Service (the “IRS”) and the Treasury Department announced their intention in Notice 2015-54 (the “Notice”) to issue regulations (the “Future Regulations”) under...more

McDermott Will & Emery

Treasury Releases Guidance for Contributions of Appreciated Property to Partnerships with Related Foreign Partners

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On August 6, 2015, 18 years after U.S. Congress authorized regulations under Internal Revenue Code Section 721(c), the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released Notice 2015-54 announcing...more

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