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
Cordasco & Company PC is a boutique CPA firm specializing in federal and state tax issues. We provide customized tax and accounting services specifically designed to help our clients capitalize on the rapidly changing tax and accounting environments.
