Layla Asali discussed the status of the Internal Revenue Service's (IRS) guidance on outbound transfers of intangible property, during a panel at the 2024 DC Bar Tax Conference. In a discussion of 2023 proposed Treasury Regulations that are intended to facilitate repatriation of intangible property to the U.S., Asali noted that notwithstanding the helpful guidance there continues to be uncertainty on many aspect of transactions that are subject to section 367(d), including the question of how to determine the basis of intangible property that has been transferred outside the U.S. in a section 367(d) transaction.