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Return to Sender – Treasury Issues Proposed Regulations under Section 367(d) Concerning Repatriation of Intellectual Property

Return to Sender – Treasury Issues Proposed Regulations under Section 367(d) Concerning Repatriation of Intellectual Property

by Lydia Chiu | May 18, 2023 | Insights

On May 2, 2023, the Treasury Department and IRS released a new set of proposed regulations (the “Proposed Regulations”) which, under certain circumstances, would eliminate the annual income inclusion required under Section 367(d)[1] when intangible property (“IP”) is...
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