The Tax Cuts and Jobs Act (TCJA) included a provision (section 14221) that appears to be an attempt to retroactively change the interpretation of code sections 367 and 482 regarding the required valuation method for the transfer of intangible property (IP) rights in the context of outbound restructuring transactions, as well as in intercompany transfer pricing arrangements.
In this article originally published by Tax Notes, A&M Managing Director Philip Antoon and Senior Adviser Kenneth Brewer discuss the implications of the TCJA’s changes to the rules for valuing IP.
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