
On Wednesday, October 9, 2024, the Treasury Department and the Internal Revenue Service (“IRS”) released final regulations (TD 9994), confirming that the application of section 367(d) to intangible property (“IP”)—e.g., patents, copyrights, trademarks, licenses, etc.—is terminated when the IP is repatriated to the United States (“U.S.”) under certain circumstances. Continue Reading Repatriate Intangible Property to the U.S. and Turn Off Section 367(d) Inclusions