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Expert Analysis

Inside The IRS Plan To Erase Goodwill Tax Exception

Law360, New York (September 24, 2015, 9:55 PM EDT) -- On Sept. 14, 2015, the IRS released proposed regulations that would significantly alter the treatment of outbound transfers of foreign goodwill and going concern value by a U.S. person to a foreign corporation. Under the proposed regulations, an outbound transfer of these types of assets will no longer be exempt from gain recognition under Section 367. As discussed below, this change will eliminate an important planning opportunity currently available in many outbound transfers. Once finalized, the proposed regulations would apply retroactively to transfers occurring on or after Sept. 14, 2015....

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