Tax Law and International Tax Law

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Article
IRS Transfer Pricing Guidance: Adjustments Based On Actual Results
The IRS has issued guidance endorsing a muscular approach to the application of "periodic adjustments" provisions. Those provisions authorize IRS adjustments of a taxpayer's pricing for transfers of high-value intangibles, including platform contribution transactions, for taxable years after the year of transfer, based on the actual, realized profitability of those intangibles in those later years
United States Tax
CD
Caplin & Drysdale
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