Jeffrey Tebbs will present, "Proposed Section 367(d) Regulations," as part of the DC Bar International Tax Series on June 22, 2023, at 12 p.m. ET. This panel will examine the recently-released proposed regulations under section 367(d), which address when intangible property previously transferred from a U.S. corporation to a foreign corporation and subject to section 367(d) is then subsequently transferred to a U.S. person. The panel will discuss the mechanics of the proposed regulations and may address open issues related to IP repatriation.

Panel:
Jeffrey Tebbs, Member, Miller & Chevalier
Rafic Barrage, Partner, Baker & McKenzie LLP
Chad Rowland, Attorney, Internal Revenue Service, Office of Associate Chief Counsel (International)
Brenda Zent, Special Advisor on International Taxation, U.S. Department of Treasury