Rocco Femia Quoted Regarding Use of Section 367(d) to Police Repatriations in Tax Notes Today

"Questioning the Use of Section 367(d) to Police Repatriations"
Tax Notes Today
11.10.14Rocco Femia was quoted during a panel presentation at the University of Chicago's Federal Tax Conference regarding the use section 367(d) to target transactions intended to repatriate earnings from foreign corporations. Notice 2012-39, which will serve as the basis of upcoming regulations, requires immediate income recognition when a U.S. parent transfers intangibles to a foreign subsidiary in exchange for cash as part of an outbound reorganization. Femia questioned whether the notice has anything to do with the impetus of section 367(d), characterizing the use of section 367(d) to police repatriations as "opportunistic."
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