October 9, 2024 Treasury Department released final regulations on the application of IRC Section 367(d) following certain repatriations of intellectual property The IRS and Treasury Department released final regulations (TD 9994) under IRC Section 367(d) concerning the repatriation of intangible property by a foreign corporation to a qualified domestic person. The final regulations adopt the proposed regulations from May 2023 (see Tax Alert 2023-0843) with some modifications. A Tax Alert is forthcoming.
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