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May 2, 2023

IRS issues proposed rules on tax implications for repatriation of intellectual property

The IRS has issued proposed regulations (REG-1240604-19) under Section 367(d) addressing situations in which intangible property that had been transferred to a foreign corporation is repatriated to certain US persons. The proposed regulations would terminate, in some situations, the continued application of certain tax provisions arising from the initial transfer. The IRS invites comments to be submitted within 60 days of May 3, 2023, when the proposed rules will be published in the Federal Register.

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor