United States - Treatment of Business Synergy for Transfer Pricing Purposes: Critical Analysis of Sections 367(d), 482 and 936 of the Internal Revenue Code and Government Proposals
- United States
- L. Freitas de Moraes e Castro
- International Transfer Pricing Journal, 2012 (Volume 19), No 2
- 15 March 2012
This article addresses the legal issue arising in the United States when the Internal Revenue Service and taxpayers face cross-border transfers of intangibles in outbound transactions (i.e. situations where the acquirer is a foreign entity), specifically where synergy is the intangible to be valued and taxed under current US transfer pricing rules.