Overview
Partner Amanda Pedvin Varma authored an article titled, "PTEP: Recent Guidance on Inbound Transactions and Looking Ahead" for Bloomberg Tax Management International Journal. The article describes Notice 2024-16, which is welcome guidance for U.S. corporations considering an inbound liquidation or asset reorganization of a first-tier CFC. The article also notes some additional PTEP questions that may be answered by the forthcoming proposed rules.
Read the article at Bloomberg Tax Management International Journal.
Reproduced with permission from Tax Management International Journal, 01/27/2024. Copyright @ 2024 by Bloomberg Industry Group, Inc. (800-372-1033) http://www.bloombergindustry.com
