Blog Posts May 15, 2019

Partnership Abuse of Entity Rule Invoked in Section 367(d) Outbound IP Transaction

Our International Tax Group explores a recent, heavily redacted Chief Counsel Advice applying the partnership abuse of entity rule to a Section 367(d) outbound IP transaction. Outbound IP transfers and Section 367(d) The partnership abuse of entity rule Interaction between the partnership abuse of entity rule and Section 367(d) successor rules Read the full advisory here. [...]Read more

The post Partnership Abuse of Entity Rule Invoked in Section 367(d) Outbound IP Transaction appeared first on Alston & Bird Tax Blog.

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