Layla Asali Comments on Treasury Regulations on Outbound Transfers of Intangibles in BNA Daily Tax Report

"Section 367(d) Intangibles Rules Target Current Abuses"
BNA Daily Tax Report
10.21.15Layla Asali commented on the U.S. Department of the Treasury's proposed regulations attacking aggressive positions on outbound transfers of intangibles during a panel discussion hosted by the D.C. Bar Taxation Section's International Tax Committee. Government officials participating in the panel discussion described the proposed regulations as attacking aggressive positions taken by taxpayers under current law. Asali raised questions as to whether the proposed limitation of the rules for outbound transfers of active business property were consistent with congressional intent. The panelists debated whether the government's concern could be summarized as a valuation dispute or whether the proposed regulations were motivated by a policy concern that extended beyond valuation.
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