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Transfer Pricing Report

IRS Still Working on Rules for Valuing Intercompany Arrangements

July 18, 2019, 8:23 PM

The IRS is working on final rules that describe how U.S. multinationals should value intellectual property transferred to offshore units—but those rules may take some time to complete, an agency official said.

“We want to do that stuff soon, but it’s not like it’s going to be out in a month or anything like that,” said Christopher Bello, Branch 6 chief at the Internal Revenue Service’s Office of the Associate Chief Counsel (International). Bello spoke July 18 at a National Association for Business Economics conference in Washington.

  • The final rules relate to 2015 temporary regulations on T.D. 9738...
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