On May 2, 2023, the Department of the Treasury and Internal Revenue Service (“IRS”) issued proposed Treasury Regulations (REG-124064-19) that would, in certain cases, terminate the application of ...

The IRS on Tuesday issued proposed regulations that would in certain cases terminate the continued application of Sec. 367(d) when intangible property is repatriated to certain U.S. persons after ...

IP, on the other hand, is a special category of intangible asset. IP is created by human intellectual or inspirational activity, and includes patents, trademarks, trade names, copyrights, trade ...