Janet Brooks
Publications
The Super Royalty: The 1984 and 1986 Tax Act Amendments Affecting Transfers of Intangibles to Foreign Subsidiaries | ||
and AbstractThe authors discuss the applicability of Section 367 of the Internal Revenue Code to the transfer of intangible property from a domestic parent company to a subsidiary. Special emphasis is given to the recent amendments to the Code. Also presented are alternatives to transferring intangibles to foreign corporations. | company corporation foreign income intangible property section transfer transferor value Volume 3 Issue 1 Page 87 | |
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