The Internal Revenue Service has issued a notice to provide guidance to multinational companies on the thorny question of transferring intangible property such as patents from a domestic corporation in the U.S. to a foreign corporation or subsidiary, noting that some repatriation transactions "raise significant policy concerns."

Notice 2012-39 addresses transactions that raise significant policy concerns involving certain transfers of intangible property by a domestic corporation to a foreign corporation in an exchange described in a Section 361exchange.  The IRS and the Treasury Department plan to issue regulations that incorporate the guidance described in the notice.  The regulations will apply to transfers occurring on or after July 13, 2012.

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