Sean Foley Cameron Taheri The US Treasury Department and Internal Revenue Service on December 15 2016 released for publication in the Federal Register final regulations (T.D. 9803), addressing the tax treatment of transfers by US persons of property – including goodwill and going-concern value – to foreign corporations in non-recognition transactions pursuant to Section 367. These regulations finalise those that were proposed in September 2015 and withdraw temporary regulations that date back from 1986.
January 27 2017