Proposed Regulations Under §367 Depart from Longstanding Policies

Tax Management International Journal
01.08.16
In this article, Layla Asali and Rocco Femia discuss Section 367(a) and §367(d), which address the outbound transfer of property by United States persons to foreign corporate transferees in non-recognition transactions. The U.S. Department of the Treasury and the Internal Revenue Service issued proposed regulations, which "champion an ahistorical and overbroad variant of the anti-tax avoidance policy of §367 to the exclusion of the general policy of nonrecognition," the authors said.
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Proposed Regulations Under §367 Depart from Longstanding Policies