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Final regs. on treatment of controlled services transactions under Sec. 482.

Publication: The Tax Adviser
Publication Date: 01-OCT-09
Format: Online
Delivery: Immediate Online Access

Article Excerpt
On August 4, the IRS issued final regulations on the treatment of controlled services transactions under Sec. 482 and the allocation of income from intangible property (T.D. 9456). The regulations also modify existing Sec. 861 regulations on stewardship expenses.

Sec. 482 allows the IRS to allocate gross income, deductions, and credits among members of a controlled group in order to prevent tax evasion or...

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