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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 - Washington Office

October 23, 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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