Page 492 - Large Business IRS Training Guides
P. 492
Real World Transfer
Pricing Impact of GILTI &
Intangible Property
Related Changes 3
Impact of 2017 TCJA’s GILTI
Transfer Pricing
Regime
& Intangible Property Changes on a
Case (Pre-TCJA):
Real World
• What might
be three primary tax minimization goals of
establishing this Intangible Property
migration structure?
• Third, minimize the Foreign tax consequences that emanate
from the post-transfer activity generated with the foreign structure.
• Did We Typically Care That Much About Foreign Tax Law
Consequences Under Pre-TCJA Paradigms (Maybe)?
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