Alston & Bird Tax Blog

International Tax Advisory: Distribution of Foreign Company Stock in Outbound Reorganization Was Indirect Disposition of Intangible Property Subject to Section 367(d) Disposition Rule

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This advisory discusses how in Chief Counsel Advice (CCA) 201321018, the IRS concluded that a U.S. target corporation’s Section 361(c) distribution of stock of a foreign corporation pursuant to a reorganization constituted an indirect disposition of intangible property, requiring the target to recognize income under the “Disposition Rule” of Section 367(d).

The advisory is provided in PDF on the Alston & Bird website: www.alston.com/advisories/int-tax-6-17-13  

Written by Edward Tanenbaum, Partner, Federal & International Tax | Alston & Bird LLP

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About Jasper L. (Jack) Cummings, Jr.

Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation.

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About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

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