Sec. 503. Limitations on income shifting through intangible property transfers

278 words·~1 min read·/bill/113/s/277/is/section-503

A research copy — for the controlling text, always check the official state or federal source. Not legal advice.

Clause

(vi)of section 936(h)(3)(B) of the Internal Revenue Code of 1986 is amended by inserting (including any section 197 intangible described in subparagraph (A), (B), or (C)(i) of subsection (d)(1) of such section) after item . Paragraph

(2)of section 367(d) of the Internal Revenue Code of 1986 is amended by adding at the end the following new subparagraph: For purposes of the last sentence of subparagraph (A), the Secretary may require— the valuation of transfers of intangible property on an aggregate basis, or the valuation of such a transfer on the basis of the realistic alternatives to such a transfer, in any case in which the Secretary determines that such basis is the most reliable means of valuation of such transfers. . Section 482 of such Code is amended by adding at the end the following: For purposes of the preceding sentence, the Secretary may require the valuation of transfers of intangible property on an aggregate basis or the valuation of such a transfer on the basis of the realistic alternatives to such a transfer, in any case in which the Secretary determines that such basis is the most reliable means of valuation of such transfers. . The amendments made by this section shall apply to transfers in taxable years beginning after the date of the enactment of this Act. Nothing in the amendment made by subsection

(a)shall be construed to create any inference with respect to the application of section 936(h)(3) of the Internal Revenue Code of 1986, or the authority of the Secretary of the Treasury to provide regulations for such application, on or before the date of the enactment of such amendment.