Date: 10/21/2020
Multinationals that previously shifted valuable intellectual property, such as patents and trademarks, outside the U.S. using partnership entities as intermediaries should start double-checking their agreements, now that the IRS deems those transactions as abusive.
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The IRS didn’t respond to a request for comment.
“This could be unique or it could be part of a bigger wave of clean up of when the IRS didn’t have specific technical regulations in place—and now they are looking back through the lens of the anti-abuse regulation which did exist then,” said Elizabeth Stevens, a Member at Caplin & Drysdale in Washington.
The memorandum says the IRS can impose tax adjustments in abusive cases.
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“Taxpayers have been getting away with a lot within the rules without anyone knowing about it for a long time,” Stevens said.
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