Title: Treatment of Business Synergy for Transfer Pricing Purposes: Critical Analysis of Sections 367(d), 482 and 936 of the Internal Revenue Code and Government Proposals
Abstract: This article addresses the legal issue arising in the United States when the Internal Revenue Service and taxpayers face cross-border transfers of intangibles in outbound transactions (i.e. situations where the acquirer is a foreign entity), specifically where synergy is the intangible to be valued and taxed under current US transfer pricing rules.
Publication Year: 2012
Publication Date: 2012-03-15
Language: en
Type: article
Indexed In: ['crossref']
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