Bloomberg Quotes Elizabeth Stevens on Partnerships Tax Rules

10.21.2020
Bloomberg Law

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.

. . .

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.

. . .

“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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