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Section 367: Mitigating the Toll Charge on Outbound Property Transfers and Stock Exchanges

A live 110-minute CPE webinar with interactive Q&A

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Tuesday, February 4, 2025

1:00pm-2:50pm EST, 10:00am-11:50am PST

Early Registration Discount Deadline, Friday, January 17, 2025

or call 1-800-926-7926
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This webinar will analyze how Section 367 applies to outbound transfers. Our international tax expert will review the guidelines for domestic transfers to foreign corporations, including tangible and intangible property transfers and exchanges for stock. He will discuss techniques to mitigate the effect of the Section 367 toll charge, including utilizing gain recognition agreements (GRAs), and the related reporting requirements for outbound transfers.

Description

Section 367 imposes a toll charge on specific property transfers to foreign corporations outside the U.S. The transfer of property between a U.S. corporation and a domestic subsidiary can be structured so that any gain on appreciated property is deferred; Section 367 was implemented so that appreciated assets transferred and sold abroad would not escape U.S. taxation. This section imposes a toll charge on certain outbound transfers to capture the applicable tax due.

In addition to tangible property, intangible property such as trademarks and patents are subject to this toll charge, as are transfers in exchange for stock. On Oct. 10, 2024, the Treasury and IRS issued final regulations under Section 367(d) pertaining to specific transfers of intangible property from foreign corporations back to the U.S. There are steps taxpayers can take and exceptions available to avoid the impact of Section 367. A GRA, for example, can defer the tax impact of Section 367 for eligible taxpayers.

Listen as our international consulting and compliance expert explains the impact of Section 367 on outbound transfers and offers advice on avoiding its consequences.

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Outline

  1. Section 367: outbound transfers
  2. Transfers by a U.S. person to a foreign corporation
  3. Transfers of intangible property
  4. Outbound transfers to stocks and securities
  5. GRAs
  6. Transactions subject to 367(b) and 367(a)
  7. October 2024 final regulations and other guidance
  8. Strategies to avoid Section 367 taxation
  9. Required reporting
  10. Other considerations

Benefits

The panel will cover these and other critical issues:

  • Tax implications of outbound transfers of tangible property by a U.S. person to a foreign corporation
  • Section 367's impact on outbound transfers of stocks and securities
  • Utilizing gain recognition agreements to mitigate the impact of Section 367
  • Applicable reporting requirements for outbound transfers

Faculty

Gurmeher Allagh
Gurmeher Allagh
International Tax Director
CBIZ

Mr. Allagh is a graduate of the University of California, Los Angeles with a bachelor's degree in economics,...  |  Read More

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