Caroline H. Ngo
By Elizabeth C. Lu, Caroline H. Ngo, Michael J. Wilder and Lowell D. Yoder on Oct 19, 2022
Posted In IRS Guidance
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 transferor receives boot in connection with the initial transfer of intangible property (IP) to a foreign corporation. The memorandum is relevant...