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(367, Whats What:) - Coggle Diagram

- - - - If transferred "outbound" i.e., US person to Foreign Co. in a transaction subject to 351 OR 361 is subject to 367(d) NOT 367(a)
        
        Transfers are treated as sales for an amount contingent upon the income produced with annual adjustments
      - "Intangible Property" is defined in 367(d)(4)
  - - - Required after a 332 liquidation of a sub to foreign parent
        
        Sub must recognize gain
  - - - Stock Asset
      - Non-Stock Asset