Inbound and offshore asset transfers by a U.S. business can be subject to immediate Federal income taxation under
§ 367.

Question

Quizplus · Accepted Answer

Section 367 of the Internal Revenue Code generally provides that transfers of property (including intangible assets) by a U.S. person to a foreign corporation in an exchange that would otherwise qualify for non-recognition treatment under the tax code (e.g., as part of a reorganization or in exchange for stock) can be subject to immediate taxation, to prevent tax avoidance through the use of foreign entities.

Inbound and Offshore Asset Transfers by a U