Internal Revenue Service May 3, 2023 – Federal Register Recent Federal Regulation Documents

Section 367(d) Rules for Certain Repatriations of Intangible Property
Document Number: 2023-08843
Type: Proposed Rule
Date: 2023-05-03
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations that, in certain cases, would terminate the continued application of certain tax provisions arising from a previous transfer of intangible property to a foreign corporation when the intangible property is repatriated to certain United States persons. The proposed regulations would affect certain United States persons that previously transferred intangible property to a foreign corporation.
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