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

Resumen

This document withdraws proposed regulations published in the Federal Register on September 10, 2003 (68 FR 53448), related to the treatment of controlled services transactions under section 482 and the allocation of income from intangibles, in particular with respect to contributions by a controlled party to the value of an intangible that is owned by another controlled party. The IRS and Treasury Department are withdrawing those proposed regulations because they have been superseded.