The IRS has submitted corrections to final regulations (T.D. 9546) that provide guidance on the treatment of controlled services transactions under section 482 and the allocation of income from intangible property.
See Tax Analysts: "IRS Corrects Final Regs on Treatment of Controlled Service Transactions," 2009 TNT 172-41, September 8, 2009
Posted by Raj Chudgar, Associate Editor, Wealth Strategies Journal

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