January 4, 2016

IRS Commensurate with Income Powers: Exploring Their Limits

Ken Brewer is an international tax practitioner and a senior adviser with Alvarez & Marsal Taxand. In this article, Brewer suggests that the periodic adjustment regulations under section 482 may be invalid to the extent that they override the statute of limitations for taxable transfers of intangible property.  

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Tax Notes: IRS Commensurate With Income Powers: Exploring Their Limits

 

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