IRS Victory: 3M Transfer Pricing Challenge Update
Tax Notes Talk
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The Commensurate With Income
Before the Tax Reform Act in 1986, there was only one section to Section 482. In 1986, they added the sentence that says income attributable to a transfer license of a tangible property shall be commensurate with the income attributable to the intangible. The relevance in this case was that the allegedly blocked income was an arm's length royalty for the license of intangible property. It came up in the Altera v Commissioner case, but I don't think a lot of people expected.
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