A provision of the Tax Reform Act of 1986 which stipulates that the arm's length transfer of intellectual property between a U.S. entity and a related foreign entity constitutes an exchange of value commensurate with the income that would otherwise be attributable to the intellectual property. In such cases, the IRS would adjust the transaction to reflect an effective transfer of income.
Related information about super royalty provision:
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Definition of super royalty provision: A provision of the Tax Reform Act of 1986 which stipulates that the arm's length transfer of intellectual property between a ...
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COMMENSURATE WITH INCOME STANDARD -- See: Super royalty provision. COMMERCIAL INTANGIBLE -- An intangible that is used in commercial activities ...
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Dec 2, 2011 ... super royalty provision, states: “In case of any transfer (or license) of intangible property… the income with respect to such transfer or license ...
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Termed the “super royalty” provision, IRC §367(d) taxes the U.S. transferor by requiring recognition of income as if the intangible property was sold to the foreign ...
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Super Efficient Refrigerator Program (SERP) · Super Royalty Provision · Law Firms: Advertise on USLegal, Inc. Reach millions of Legal Consumers every month.
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May 4, 2009 ... Super-royalty provision applicable -. §367(d)(2)(A). Exception for foreign based goodwill which is transferred. Planning option: use a licensing ...
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Mar 29, 2012 ... payments per super-royalty provision of §367(d)(2)(A). The annual payment is ordinary in character from sources without the United States ...
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Further consider the “super-royalty” provision in Code §482 – requiring periodic adjustments. p.755. Cost Sharing Arrangements p.755. Reg. §1.482-7T (2009).