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Intangible Property Outbound Transactions

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

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