The Resource Contingent-payment R&D service arrangements under the services temporary regulations

Contingent-payment R&D service arrangements under the services temporary regulations

Label
Contingent-payment R&D service arrangements under the services temporary regulations
Title
Contingent-payment R&D service arrangements under the services temporary regulations
Creator
Subject
Language
eng
Summary
On 31 July 2006 the U.S. tax authorities released long-awaited temeporary and proposed regulations on the tax treatment of intercompany service transactions and intangible property ownership. One of the novel features of the temporary regulations is their explicit authorization of contingent-payment services agreements. This article discusses how taxpayers might apply the temporary regulations' contingent-payment services rules to structure related party research & development services contracts, including empirical observations on the use of uncontrolled contingent payment arrangements, potential methods for determining an arm's length contingent payment, commensurate-with-income standard and contingent-payment arrangements, contingent-payment arrangements and other alternatives compared, and IRS application of contingent-payment approach
Citation source
In: Journal of international taxation. - New York. - Vol. 18 (2007),
http://library.link/vocab/creatorName
  • Herr, T.M
  • Zollo, T.M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • intangibles
  • research and development
  • intra-group services
Label
Contingent-payment R&D service arrangements under the services temporary regulations
Instantiates
Publication
Label
Contingent-payment R&D service arrangements under the services temporary regulations
Publication

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