Monte A. Jackel & Audrey Ellis (both of PricewaterhouseCoopers, Washington, D.C.) have published Transfer of the Use of Property: Time for Clarification, 129 Tax Notes 1011 (Nov. 29, 2010):
In this article, the authors review the current law for transfers of the use of property under § 721 and discuss a proposal to treat a transfer of all substantial rights in intangible property as a trasfer of property for this purpose.
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