Treatment of Services Under Section 482 Allocation of Income and Deductions From Intangibles Stewardship Expense; Correction

Zusammenfassung

This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations, notice of proposed rulemaking, and notice of public hearing that was published in the Federal Register on Friday, August 4, 2006 (71 FR 44247) relating to the treatment of controlled services transactions under section 482. These regulations also provide guidance regarding the allocation of income from intangibles, in particular with respect to contributions by a controlled party to the value of an intangible owned by another controlled party, as it relates to controlled services transactions, and modify the regulations under section 861 concerning stewardship expenses to be consistent with the changes made to the regulations under section 482.