The IRS on Wednesday issued final regulations (T.D. 9994) that, in certain cases, terminate the continued application of Sec. 367(d) when intangible property is repatriated to certain U.S. persons ...
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 having ...
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