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IFA USA Miami Region Luncheon Presentation
Miami, Florida, 33133
December 3rd, 2015
12:00 PM , Florida, USA
Event Speaker
James H. Barrett
Jeffrey L. Rubinger
Robert H. Moore
Steven Hadjilogiou
Event Description
Discussions Consist of:
- Newly Proposed Regulations Under Code Sections 367(d) and 482 arguably repealing the Foreign Goodwill and Going Concern Exception for IP Migrations by US Multinationals.
- Notice 2015-54 mandating partnership allocations for transfers of IP to foreign partnerships. New Code Section 956 Rules Applying Aggregate Theory to the Ownership of CFC stock by foreign partnerships.
- Newly Proposed Code Section 367 Regulations Containing Favorable Clarifications for Foreign to Foreign Reorganizations
-Brief Description of Final OECD Base Erosion and Profit Shifting Report advocating a broad range of changes in the taxation of multinational enterprises.
- Newly Proposed Regulations Under Code Sections 367(d) and 482 arguably repealing the Foreign Goodwill and Going Concern Exception for IP Migrations by US Multinationals.
- Notice 2015-54 mandating partnership allocations for transfers of IP to foreign partnerships. New Code Section 956 Rules Applying Aggregate Theory to the Ownership of CFC stock by foreign partnerships.
- Newly Proposed Code Section 367 Regulations Containing Favorable Clarifications for Foreign to Foreign Reorganizations
-Brief Description of Final OECD Base Erosion and Profit Shifting Report advocating a broad range of changes in the taxation of multinational enterprises.