Partnership Abuse of Entity Rule Invoked in Section 367(d) Outbound IP Transaction

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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.