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IRS Issues Final and Temporary Intercompany Services Regulations. By Kerwin Chung (Washington D.C.) and Larry Shanda (New York) Reviewed by Alan Shapiro (Chicago). The IRS on July 31 issued final and temporary section 482 regulations regarding the treatment of intercompany service transactions and the allocation of income from intangibles. The new regulations, issued principally under new Treas. Reg.§1.482-9T, replace the current 1968-era guidance, and contain many changes to address issues raised by taxpayers and commentators following the issuance of
proposed regulations in 2003.
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