Significant controversy has arisen with regard to the application of Section 199 to intercompany transactions. In the March 2006 issue of AICPA's The Tax Advisor, Deloitte Tax LLP's own Gary Hecimovich and Joseph Vetting give a background summary of the Section 199 regulations that explain how the proposed regulations have clarified the treatment of intercompany transactions. Read the full article attached below.
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Proposed Section 199 Regulations Clarify Treatment of Intercompany Transactions (126 KB)
Read the article by Gary Hecimovich and Joseph Vetting