Andersen Managing Director Joe Calianno's comments are featured in the recent Tax Notes article, Proposed Regs. Terminate Inclusion Rules for IP Repatriations.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. Joe said that the literal application of the current regulations could lead to inappropriate results. He also pointed out that taxpayers could not rely on the proposed regulations until they are finalized. Joe chaired a panel discussion that addressed this topic at the ABA Tax Section's 2023 May Tax Meeting in Washington, D.C. on May 5.