Transfer Pricing alert: 09-22IRS issues final regulations on treatment of controlled services |
The Internal Revenue Service has released final regulations (TD 9456) on the treatment of controlled services transactions under section 482 and the allocation of income from intangible property, on the day the temporary regulations issued in 2006 were scheduled to expire. The final regulations also modify regulations under section 861 concerning stewardship expenses to be consistent with the changes made to the regulations under section 482.
We are preparing an alert on the final regulations that will discuss any changes from the temporary regulations, and new features (if any) in the final regulations.
TP alert 09-022: IRS final regulations and removal of temporary regulations
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