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IRS Releases Memorandum Regarding Advance Payments of Section 367(d) Inclusions

On September 23, 2022, the Internal Revenue Service (IRS) released a memorandum (AM 2022-003) concluding that taxpayers cannot make advance payments of section 367(d) inclusions except in the limited situation in which the US...more

The New Deduction for Foreign-Derived Intangible Income

The 2017 tax reform legislation added section 250 to the Internal Revenue Code, effectively creating a new preferential tax rate for income derived by domestic corporations from serving foreign markets. The new deduction is...more

Focus on Tax Strategies & Developments - October 2015

Regulatory Developments Under ยง 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

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