Partnership Abuse of Entity Rule Invoked in Section 367(d) Outbound IP Transaction
Our International Tax Group explores a recent, heavily redacted Chief Counsel Advice applying the partnership abuse of entity rule to a Section 367(d) outbound IP transaction.
Outbound IP transfers and Section 367(d)
The partnership abuse of entity rule
Interaction between the partnership abuse of entity rule and Section 367(d) successor rules
Read the full advisory here. [...]Read more