About This Course
The statutory and regulatory history of US price controlled transactions between controlled taxpayers involving intangible property is a fascinating field of study. This CLE course will explore this issue as well as the new provisions signed into law by the Tax Cuts & Jobs Act. The course will explain the concepts surrounding intangible property that inform the US transfer pricing between the IRS and taxpayers and the IRS and outside government with whom we maintain tax treaties including commensurate with income principles, aggregation, cost sharing, Pillar 1 and Pillar 2 of the OECD’s proposals and realistic alternatives.
