Clarification or modification? The tax treatment of the outbound transfer of goodwill, going concern value, and workforce in place to a foreign corporation

Resource Information

The work Clarification or modification? The tax treatment of the outbound transfer of goodwill, going concern value, and workforce in place to a foreign corporation represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Clarification or modification? The tax treatment of the outbound transfer of goodwill, going concern value, and workforce in place to a foreign corporation

Creator

• Zollo, T.M

Subject

• intangibles
• outbound transaction

Language

eng

Summary

The Obama Administration's "Green Book" on tax reform, released in May 2009, included a proposal to limit the "shifting of income" out of the United States through intangible property transfers. This proposal would clarify the definition of intangible property. The author describes the relevant sections and regulations, legislative history and analyses the proposal, and concludes that the proposal would represent a change in the law and not a clarification

Citation source

In: Tax management international journal. - Arlington. - Vol. 39 (2010),

Geographic coverage

International

Language note

English