Treasury Plans More Guidance on Intellectual Property Transfers

The IRS is planning further guidance on transfers of intellectual property out of and into the US, to address questions that weren’t dealt with in proposed rules issued in May, a Treasury Department official said Wednesday.

There will be “subsequent packages” of rules—one or possibly more—relating to Section 367(d) following the May proposal, said Brenda Zent, a special adviser in Treasury’s Office of International Tax Counsel, speaking on an American Bar Association Tax Section webinar. She didn’t provide any timing for when the additional rules packages might be issued.

Section 367(d) requires a US company that moves intellectual property ...