The U.S. IRS and Treasury have issued proposed regulations, Section 367(d) Rules for Certain Repatriations of Intangible Property, which were published in the Federal Register on 3 May 2023. Under Section 367(d), it is essentially provided that when a U.S. person transfers intangible property to a foreign corporation in certain cases, the U.S. person is considered to receive deemed income in respect of the intangible property. Specifically, the U.S. transferor is treated as receiving amounts…