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Temporary Regs. Under Sec. 482 Coordinate Transfer-Pricing Rules with Other Code

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. C ...

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The Valuation of Trademark-Related Intangible Property

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 pr ...

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