Obama Seeks to Tax Outbound Transfers of Workforce in Place

Journal of International Taxation, September 2009

Hidden within the Obama Administration's proposed far-reaching changes is a little-noticed provision that would "clarify" the definition of intangible property to include workforce in place, goodwill, and going concern for purposes of Sections 367(d) and 482 "to prevent the inappropriate shifting of income outside the United States," as discussed in this Journal of International Taxation article written by Lewis J. Greenwald, Douglas S. Stransky and Eric J. Fuselier.

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