Notice 2012-39: New rules for outbound reorganizations

July 2012


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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Doug McHoney
Outbound Co-leader, International Tax Services
Tel: +1 (312) 298 2527

Calum Dewar
International Tax Outbound Services co-leader
Tel: +1 (646) 471 5254

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