Tax Implications of Contributing Appreciated Property Overseas
Tax Notes Federal, Vol. 179, N. 3, 2023
6 Pages Posted: 18 May 2023
Date Written: April 17, 2023
In this article, Narotzki and Shanan examine the application of section 367 to section 351 exchanges and the income inclusion issues that may arise upon a U.S. person’s contribution of property to a foreign entity.
Keywords: Tax, International Tax, Corporate Tax, Section 351, Section 367
JEL Classification: K34
Suggested Citation: Suggested Citation
Narotzki, Doron and Shanan, Tamir, Tax Implications of Contributing Appreciated Property Overseas (April 17, 2023). Tax Notes Federal, Vol. 179, N. 3, 2023, Available at SSRN: https://ssrn.com/abstract=4448695
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