Our Federal Tax Group explores how affiliates selling property to each other at book value could cause more problems than it solves.
- Book value
- Fair market value
- The tax consequences
Read the full advisory here.
Tag Archives: section 482
International Tax Advisory: Through the Looking Glass: Reporting by Foreign-Owned Disregarded Entities
▪ Written by Edward Tanenbaum and Heather RipleyIn the wake of the Panama Papers leak, the IRS and Treasury have announced proposed regulations to require significant reporting by foreign-owned domestic disregarded entities. Our International Tax Group considers the implications of this anticipated regulatory burden.
Proposed Sec. 367 Regs Say Goodbye to Goodwill Exception
▪ Written by Heather Ripley
Citing aggressive taxpayer positions, recently proposed regulations do away with the foreign goodwill exception to gain or income recognition for outbound transfers under Section 367. The rules also restrict the type of property eligible for the active business exception.
Reasons for Change
Per the preamble, taxpayers interpret Section 367 and the regulations in one of two ways when claiming favorable treatment of foreign goodwill and going concern value. One interpretation argues that goodwill and going concern value are not IP within the meaning of Section 936(h)(3)(B) and thus not subject [...]Read more