CCH Tax Day Report The IRS has issued final regulations that generally eliminate the favorable tax treatment of outbound transfers of foreign goodwill and going concern value in certain nonrecognition transactions described in Code Sec. 367 and narrow the scope of the active trade or business exception of Code Sec. 367(a)(3). The regulations finalize proposed […]
The post Final Regulations Eliminate Favorable Tax Treatment of Outbound Transfers of Foreign Goodwill and Going Concern Value and Modify Active Trade or Business Exception (T.D. 9803) appeared first on Tax & Accounting Blog.