The treatment of intangible property rights in international tax planning

Article Abstract:

Tax planning for international property rights of intangible assets involves IRC section 482 and other areas. IRC 482 concerns include arm's length royalty rates, the comparable profit interval, the method of exact comparables, payments for technical services, cost sharing, intercompany pricing and blocked income. Other areas include royalties under Subpart F, IRC 1031 for exchanges, IRC 367(d) for transfers, IRC 351 for patents and sales of patents or knowledge.

International aspects, Tax planning, Transfer pricing

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Indopco & Newark: defining the intangible "asset" in the larger cost recovery context

Article Abstract:

Taxation of intangible assets should be revised. The definition of such assets has been challenged in INDOPCO, Inc. v Commissioner and Newark Morning Ledger Co v United States. Investment bankers' professional fees were capitalized as intangibles in INDOPCO, while Newark may deny amortization of every intangible. The equilibrium approach to cost recovery for intangibles leads to errors such as inconsistent positions by the government in the two tax cases.

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"Money" and "property (other than money)": an exploration of "amount realized" under section 1001(b)

Article Abstract:

IRC section 1001(b) is unclear for its distinction between money and property for amounts realized in asset transfers, depending on whether the taxpayer uses accrual or cash basis accounting. Seven possible transactions come under IRC 1001(b). The only transaction of the seven which is easily understood by IRC 1001(b) is a taxable property transfer in which the buyer gives stock and it doesn't matter whether accrual or cash basis accounting is used.

Accrual basis accounting, Cash basis accounting

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