Page 482 - Large Business IRS Training Guides

2017 TCJA
–

Transfer Pricing Impact of
GILTI (cont’d)

Pricing Related Implications of
Transfer

GILTI:

may implicate both greater and
• GILTI regime mechanics
reliance on transfer pricing determinations:
lesser

• GILTI related transfers of intangible and tangible property

between related parties may require IRC 482 related valuation

determinations.

• GILTI calculations
may in part be made independent of IRC 482
for example Qualified Business
valuation related determinations,
Investment (“QBAI”) related adjustments that utilize a
Asset
determination applied to the tax basis of QBAI assets.
formulary

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