New temporary regulations address key Section 482 rulesThe IRS recently issued temporary and proposed
regulations on the treatment of controlled services
transactions under section 482, and the allocation of
income with respect to intangibles contributed by a
controlled party. The temporary regulations also modify
the regulations under section 861 regarding “stewardship”
expenses to be consistent with the changes made to the
section 482 regulations. While the guidance is meant to
be taxpayer-favorable, Pharma companies may find some issues to be worthy of further consideration.
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