The IRS on Wednesday issued final regulations (T.D. 9994) that, in certain cases, terminate the continued application of Sec. 367(d) when intangible property is repatriated to certain U.S. persons ...

On May 2, 2023, the Department of the Treasury and Internal Revenue Service (“IRS”) issued proposed Treasury Regulations (REG-124064-19) that would, in certain cases, terminate the application of ...

The IRS on Tuesday issued proposed regulations that would in certain cases terminate the continued application of Sec. 367(d) when intangible property is repatriated to certain U.S. persons after ...

Intangible assets include both "traditional" intangible assets and intellectual property (IP). "Traditional" intangible assets can include the company's customer lists, vendor relationships, license ...

In In re Estate of Debra E. Hunt v. Arabia Vargas, a trial court granted summary judgment interpreting a will to devise a large share of the testatrix’s personal property to her life partner. No.

Forbes contributors publish independent expert analyses and insights. Marie Sapirie writes about federal tax issues and litigation. The long-absent definition of real property for like-kind exchanges ...

At the end of the Tax Court’s 2016 opinion in Medtronic, a short section briefly summarizes and summarily rejects what the opinion describes as the IRS’s “alternative allocation under section 367(d).” ...

The state Department of Transportation has expanded the definition of what it can seize via eminent domain. It long has condemned land – or other property that you can touch or see – to make way for ...

Intangible assets create a need for special tax accounting for small businesses. An intangible asset is "an identifiable non-monetary asset without physical substance," according to Deloitte. The ...

Tangible property refers to real property such as real estate or physical goods. Intangible property, such as intellectual property, is a different form of property ...