IRS Issues Guidance on Transfers of Intangible Property

On July 30, 2012, the Internal Revenue Service (IRS) issued Notice 2012-39 to provide guidance for the treatment of transfers of intangible property (including intellectual property) by a domestic corporation to a foreign corporation. The guidance in the Notice addresses concerns that ‚Äúcertain taxpayers are engaging in transactions intended to repatriate earnings from foreign corporations […]