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outbound liquidation

Taxpayers Can Be Somewhat “GRAteful” for New Rules on Gain Recognition Agreements

November 26, 2014 By Heather Ripley

This November the IRS has given some taxpayers subject to reporting on outbound property transfers to foreign corporations something to be thankful for. Under Section 367(a) of the Code, if a US person transfers property to a foreign corporation in a Section 332, 351, 354, 356, or 361 transfer or exchange, the foreign corporation generally is not treated as a corporation for purposes of determining the US transferor’s gain on the transfer. This rule typically means that the US person will recognize gain on what would otherwise be a non-taxable transfer. The regulations offer exceptions [...]Read more

Filed Under: International - Outbound Tagged With: foreign corporation, gain recognition agreement, outbound liquidation, reporting, Section 367

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