Developments in the Application of Section 367(a) to Transfers of Property to Foreign Corporations

Mr. Pugh traces the history of section 367 and details the important changes in that provision and the impact it will have on "outbound" transactions. Professor Gann's presentation deals with two major abuses in the foreign area covered by the Senate Finance Committee Staff Report, with specific emphasis on the concept of deferral in our international tax system, where earnings and profits are not taxed until actually brought back to the United States.