The § 367 Cross-Border Transfer Rules Seem to Counteract Other

question 88

Essay

The § 367 cross-border transfer rules seem to counteract other favorable tax provisions that allow the taxpayer to defer gross income (e.g. §§ 351 and 368.) What is the rationale for eliminating this deferral? Provide two examples of transactions to which § 367 would apply.

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Definitions:

Sexually Explicit Material

Content that shows or describes sexual activities in detail, intended to stimulate erotic rather than aesthetic or emotional feelings.

Street Hustlers

Individuals, often young, who engage in sex work or other illicit activities on the streets to earn money.

Chickenhawks

A slang term used to describe an older man who seeks out younger partners, particularly in gay communities.

Emotional Intimacy

A deep level of closeness between individuals, marked by sharing feelings, thoughts, fears, and desires.