U.S. Tech Startups: Pending Legislation on American Global Entrepreneurs, Job-Creators and Innovators
…ompany transactions and Section 482 on recharacterization to prevent tax abuses from artificial transactions lacking economic substance). Such a regime would increase the uncertainty of tax liability in situations where intercompany transactions could be subject to dispute, upon audit, as to whether the taxpayer had made a correct judgment as to the fair value of intercompany sales, licenses and services. As to such transactions, existing IRS regu…