Regulations Clarify Arm’s-Length Standard for Transfer-Pricing Rules The temporary regulations provide that the arm’s-length standard of Sec. 482 applies to all controlled transactions without regard to the form or character of the transactions, and they are particularly concerned with tax-favored transfers of assets outside the U.S. Jay L. Camillo, M.A. (international relations), Atlanta, and Kenneth P. Christman Jr., J.D., Washington, explain. To read the full article in The Tax Adviser, click: Temporary Regs. Under Sec. 482 Coordinate Transfer-Pricing Rules with Other Code.
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A Primer on the Approaches and Issues Involved in Valuing Trademarks Valuation analysts are often called on to perform valuation, damages, and transfer price analyses of trademark-related intangible property for various purposes. This discussion describes the valuation of trademarks within the context of both financial accounting and income tax accounting (in particular, tax-related intercompany transfer pricing) and summarizes the generally accepted trademark analysis approaches and methods. And, this discussion presents three examples, using different analytical methods, to illustrate the analysis of trademarks.