Richard L. Doernberg (Emory) has published Taxation Silos: Embedded Intangibles and Embedded Services Under U.S. Law, 41 Tax Notes Int’l 561 (Feb. 13, 2006), also available on the Tax Analysts web site as Doc 2006-1081, 2006 WTD 31-11. The article discusses the U.S. Treasury’s proposed transfer pricing regulation containing a special rule for services transactions that "effect a transfer of intangible property" and summarizes related judicial and administrative rulings.
Doernberg on Taxation Silos: Embedded Intangibles and Embedded Services Under U.S. Law
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