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Tighter Rules Issued on Adjustments for High-Value Intangibles

January 1, 2025
Tighter Rules Issued on Adjustments for High-Value Intangibles

Tighter Rules Issued on Adjustments for High-Value Intangibles

New IRS guidance clarifies that periodic adjustments are mandatory for high-profit intangible transactions and cost-sharing arrangements. The rule stresses using actual profit results for adjustments, not just arm's length estimates, and raises the bar for documentation.

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