U.S. Final Rules for Repatriations of Intangible Property Subject to Section 367(d)

The U.S. IRS and Treasury have issued final regulations, Section 367(d) Rules for Certain Repatriations of Intangible Property, which were published in the Federal Register on 10 October 2024. Under Section 367(d), it is essentially provided that when a U.S. person transfers intangible property to a foreign corporation in certain cases, the U.S. person is considered to receive deemed income in…
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