Gain a better understanding of the updated regulations under Section 367(d).
On December 15, 2016, the IRS issued retroactively effective regulations which tax the transfer of outbound goodwill and going concern value to foreign corporations under section 367(d). These regulations are a departure from 30 years of IRS guidance which had treated goodwill and going concern as not included within the intangibles subject to tax under section 367(d). This change poses burdens for taxpayers incorporating a foreign branch and may be used by the IRS to supplement transfer pricing arguments. This topic will help taxpayers to identify foreign goodwill and going concern value in an outbound transfer and the tax results of such a transaction. The new 367(d) regulations could result in tax liabilities of millions of dollars for unwary taxpayers. This information is critical for planning outbound business transfers under the changed rules.Agenda
Faculty
Caitlin R. Tharp
Steptoe LLP
- Associate in the Washington, D.C. office of Steptoe & Johnson LLP
- Practice emphasizes complex federal tax matters for corporate and pass-through taxpayers, including federal tax credits and international tax, as well as tax controversies before the IRS and in litigation
- LL.M degree in Taxation, J.D. degree, Georgetown; B.A. degree, Stanford
- Can be contacted at 202-429-1391 or [email protected]
Robert J. Kovacev
Steptoe LLP
- Partner in the Washington, D.C. office of Steptoe & Johnson LLP
- Practice emphasizes complex federal tax matters for corporate and high net worth taxpayers, including international tax, transfer pricing, and federal tax credits, as well as tax controversies before the IRS and in litigation
- Former senior litigation counsel in the United States Department of Justice, Tax Division, responsible for litigating some of the largest and most complex civil tax cases in the nation
- Recipient of several awards, including the John Marshall Award, the highest award for trial of litigation given by the Department of Justice
- Can be contacted at 202-429-6462, [email protected] or on Twitter® @RobKovacev
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