Page 222 - International Taxation IRS Training Guides

Intangible
Property Transfers

 TCJA
clarifies the definition of “intangible property”
IRC 936(h)(3)(B) which applies for purposes of
under

on outbound transfers under IRC 367(d) and
the rules

on transfer
pricing transactions under IRC 482

 Definition of “intangible property” now
expressly

includes:

• Goodwill,

• Going Concern Value,

• Workforce
in place, and
• Any
other item the value or potential value of which is not
the services of any individual
attributable to tangible property or

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