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Rule on IP Transfer Back to US Targeted for End of 2022: IRS

Sept. 19, 2022, 6:24 PM

The IRS is still aiming to issue regulations on the repatriation of intellectual property by the end of the year, an IRS official said Monday.

The comments from Andrew Wigmore, a senior counsel in the IRS Office of Associate Chief Counsel (International), reaffirm past comments from the Treasury Department that the IRS is working to get the regulation under Section 367(d) completed by the end of 2022. Wigmore spoke Monday at a Practising Law Institute event.

  • Treasury has described the planned regulation as a targeted rule that deals with turning off a deemed inclusion for repatriations of intellectual property, ...