Tax Reform Series 48 – Limits on Income Shifting Through Intangible Property Transfers


Plain Language of Change:

  • Changes the definition of intangible property

  • Workforce in place, goodwill (both foreign and domestic) and going concern value are intangible property

  • Codifies use of the realistic alternative principles to determine valuation with respect to intangible property transactions in connection with taxing the transfer of intangible property by a domestic corporation to a foreign corporation.

Detailed Analysis of Limits on Income Shifting Through Intangible Property Transfers

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