IP Repatriation: Effects of the Proposed Section 367(d) Regs

Nov 30, 2023

In May the IRS released proposed regulations (REG-124064-19) under section 367(d). These regulations could provide an impetus for companies, such as innovative technology and life sciences companies that previously transferred intellectual property outside the United States, to consider moving their IP back.

In this Tax Notes International article, Marianne Kane and Daniel Moyer explain the tax and accounting implications of the proposed regulations under section 367(d) concerning the repatriation of intellectual
property to the United States.

Read the article 

If your organization has previously transferred intellectual property outside the United States and is considering moving your IP back, our Corporate Tax team is here to assist. Get in touch with us today.