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:

Perpetrator

A person who carries out a harmful, illegal, or immoral act.

Anonymous

Describes a person, action, or situation where the identity is unknown or not disclosed, offering privacy or secrecy.

Hostile Expectation Bias

The tendency to assume that people will react to potential conflicts with aggression.

Domestic Battle

A conflict or struggle occurring within a household, often between family members or domestic partners.