Historically, many organizations have conducted goodwill and indefinite-lived intangible asset impairment testing by collaborating with valuation professionals and other advisers to measure fair value ...

After nearly a decade of development, the California Franchise Tax Board promulgated changes to its market-based sourcing regulation for sales of other than tangible personal property. The amended ...

Our International Tax Group explores a recent, heavily redacted Chief Counsel Advice applying the partnership abuse of entity rule to a Section 367(d) outbound IP transaction. Outbound IP transfers ...

Investopedia contributors come from a range of backgrounds, and over 25 years there have been thousands of expert writers and editors who have contributed. Goodwill is a kind of intangible asset; it ...

At the end of the Tax Court’s 2016 opinion in Medtronic, a short section briefly summarizes and summarily rejects what the opinion describes as the IRS’s “alternative allocation under section 367(d).” ...