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Joint Committee on Taxation Analyzes Administration's Transfer Pricing Proposals and Suggests Three Additional Changes by Robert T. Cole
Alston & Bird LLP
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October 26, 2009
Previously published on October 15, 2009
On May 11, 2009, the Obama Administration (the "Administration") released the "General Explanations of the Administration's FY 2010 Revenue Proposals" (the "Green Book"). The Green Book describes several international tax proposals (the "Administration's Proposal") that, if enacted, would affect many aspects of U.S. federal income taxation. One purpose of the Administration's Proposal is to "limit shifting of income through intangible property transfers" and, to that end, it proposes three changes to the transfer pricing rules.
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