Notice 2012-39: New rules for outbound reorganizations

US Outbound Newsalert

Today the IRS and Treasury issued Notice 2012-39, providing that in an outbound reorganization, boot received by the US transferor will be treated as a prepayment of the section 367(d) royalty, and thus currently includible in income, to the extent the boot is attributable to section 936(h)(3)(B) intangible property.

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