Andersen Managing Director Joe Calianno's comments are featured in the recent Tax Notes article, IP Repatriation Regs Reflect Concern Over ‘Scope Creep.'Under the proposed regulations (REG-124064-19), annual income inclusions under Sec. 367(d) would be terminated on repatriated intangible property (IP) previously transferred abroad if certain conditions are met. The article included comments made during a panel discussion Joe chaired at the ABA Tax Section's 2023 May Tax Meeting in Washington, D.C. on May 5. During the discussion, Joe cited concerns over the applicability date of the proposed rules, which do not have reliance language and would apply when finalized.