JD Supra

Proposed Regulations Issued for Repatriations of Intangible Property under Section 367(d)

On May 2, 2023, the Department of the Treasury and Internal Revenue Service (“IRS”) issued proposed Treasury Regulations (REG-124064-19) that would, in certain cases, terminate the application of ...
Law

The Slow Expansion of Conversion Claims To Cover Intangible Property

While a claim of conversion has grown to extend beyond tangible property to keep up with computerized use, courts are still grappling with how far to extend the tort. In their Commercial Division ...
JournalofAccountancy

Proposed regs. provide rules for repatriation of intangible property

The IRS on Tuesday issued proposed regulations that would in certain cases terminate the continued application of Sec. 367(d) when intangible property is repatriated to certain U.S. persons after ...
JD Supra

Court Holds That Devise Of “Personal Property” In A Will Included Tangible And Intangible Property, Including Money In Bank Accounts

In In re Estate of Debra E. Hunt v. Arabia Vargas, a trial court granted summary judgment interpreting a will to devise a large share of the testatrix’s personal property to her life partner. No.
IPWatchdog

‘Unalienable Rights’: Understanding America’s Growing Disdain for Physical and Intangible Property

“Starting first with the Napster generation and the view that sharing copyrighted music is somehow an unalienable right in and of itself, the disregard for creators not only transcended the public but ...