The IRS recently released new regulations relating to IRC §§ 367 and 482. Specifically, the September 14, 2015 release focuses on two areas:
1.The most important aspect of the temporary regulations under IRC § 367 are a significant narrowing of the scope of property that is subject to the “active trade or business” exception provided in IRC § 367(a), and (2) the elimination of the exception for transfers of foreign goodwill and going concern value under IRC § 367(d).
2.The temporary and final regulations under IRC § 482 apply to: (1) two or more controlled transactions that are interrelated and (2) controlled transactions that implicate two or more provisions of the code or regulations.
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