Section 367

4 1976 which does not involve the transfer of property to or from a united states person a taxpayer shall have for purposes of such section until 183 days after the date of the enactment of this act oct.

Section 367. Section 367 d and the rules of this section shall not apply in the case of an actual sale or license of intangible property by a u s. In the case of any exchange described in section 367 of the internal revenue code of 1986 formerly i r c. Transferor to a foreign corporation.

Section 367 a section 367 a 1 generally provides that if a united states person transfers property to a foreign corporation in connection with an exchange described in section 332 351 354 356 or 361 the foreign corporation will not be treated as a corporation for purposes of determining the extent to which gain is recognized on the transfer. 4 1976 which does not involve the transfer of property to or from a united states person a taxpayer shall have for purposes of such section until 183 days after the date of the enactment of this act oct. Person to a foreign corporation.

4 1976 to file a request. 4 1976 to file a. 1954 as in effect on december 31 1974 in any taxable year beginning after december 31 1962 and before the date of the enactment of this act oct.

Irc 367 b provides that in the case of any exchange described in irc 332 351 354 355 356 or 361 in connection with which there is no transfer of property described in irc 367 a 1 a foreign corporation shall be considered to be a corporation except to the extent provided in regulations which are necessary or appropriate to prevent the avoidance of federal income taxes. If an adjustment under section 482 is required with respect to an actual sale or license of intangible property then section 367 d and the rules of this section shall not apply with respect to the required adjustment.