Internal Revenue Bulletin:  2009-33 

August 17, 2009 


Table of Contents

T.D. 9456 T.D. 9456

Final regulations under section 482 of the Code provide guidance regarding the treatment of controlled services transactions and the allocation of income and deductions from intangible property, in particular with respect to contributions by a controlled party to the value of intangible property owned by another controlled party. The regulations also modify the regulations under section 861 concerning stewardship expenses to be consistent with the changes made to the regulations under section 482.

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