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United States | Proposed regulations would turn off IRC Section 367(d) following certain repatriations of IP

|Tax Alerts, National/Federal Taxation|United States
United States

  • The proposed regulations include a taxpayer-favorable rule that would remove a significant disincentive to repatriating previously "outbounded IP."
  • Taxpayers evaluating whether to repatriate IP subject to IRC Section 367(d) are encouraged to consider whether the proposed regulations would present a repatriation opportunity that simplifies their operating model and aligns IP ownership with the functions and employees associated with the IP.

In proposed regulations (REG-124064-19; Proposed Regulati…

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