No Tulip Bulbs Here! What is a non-fungible token (NFT)? How are NFTs valued? This article discusses NFTs and the valuation challenges these present. What is a non-fungible token (NFT)? Recently, the media has seemed to catch on to the new(ish) invention—NFTs. Even the recent episode of Saturday Night Live (SNL) has featured an entertaining segment explaining the nature of NFTs to the rhythmic beat of an Eminem song. NFT is a unique, non-interchangeable digital asset backed by blockchain ledger technology. Non-fungible characteristic of these tokens or assets refers to the unique or scarce and non-replicable nature of this digital-crypto…
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Reflections on the Ninth Circuit’s Decision in Amazon.com, Inc. v. Commissioner What is included when valuing intangibles assets for transfer pricing purposes? This is an issue that was addressed once by the U.S. Tax Court and more recently, the Ninth Circuit Court of Appeals. In a unanimous decision by the U.S. Court of Appeals for the Ninth Circuit (issued on August 16, 2019) the court of appeals affirmed the decision of the U.S. Tax Court in Amazon.com, Inc. v. Commissioner, 148 T.C. 108 (March 23, 2017). The court held that intangible assets under the U.S. transfer pricing regulations, under Section…