Plain Language of Change:
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Changes the definition of intangible property
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Workforce in place, goodwill (both foreign and domestic) and going concern value are intangible property
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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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