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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Contacts
- Doug McHoney
- International Tax Outbound Services co-leader
- Tel: +1 (513) 361 8165
- Michael Urse
- International Tax Outbound Services co-leader
- Tel: +1 (216) 875 3358
- Email ITS
