All In: The IRS’s High-Stakes Bet on Periodic Adjustments

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All In: The IRS’s High-Stakes Bet on Periodic Adjustments

  • By Elizabeth J. Stevens and J. Clark Armitage

Elizabeth J. Stevens and J. Clark Armitage critique Treasury regulations and IRS guidance governing periodic adjustments to the pricing of transfers of intangible property, and they analyze ways for controlled taxpayers to adapt to and mitigate the risk of such adjustments.

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