IRS proposes rules on gain recognition agreements for outbound transfers
The IRS has issued proposed regulations regarding the implications of the failure to file or comply with documentation requirements to qualify for non-recognition of gain in ‘outbound’ transfers of certain property to foreign corporations. As summarised in this article from DLA Piper, the proposed regulations (REG-140649-11), issued on 30 January 2013, affect four different areas of the current rules.
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