IRS Memo May Change IP Royalty Tax Prepayment Planning

By: William R. Skinner

Fenwick tax partner William Skinner recently published an article in Law360 discussing the IRS ruling that a taxpayer that has contributed IP offshore under § 367(d) cannot prepay contingent § 367(d) royalties.

Read how this IRS ruling takes a different approach from earlier guidance. 

Full article here


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