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Finanse publiczne · 10.10.2024

Section 367(d) Rules for Certain Repatriations of Intangible Property

This document contains final regulations that 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 final regulations affect certain United States persons that previously transferred intangible property to a foreign corporation.

Source: Federal Register — Department of the TreasuryOpen original release →