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Tax Lawyer, Vol. 55, No. 3 UNTANGLING THE STOCK OPTION COST SHARING LOOPHOLE 761 761 UNTANGLING THE STOCK OPTION COST SHARING LOOPHOLE Damian Laurey* I. INTRODUCTION Intercompany transfer pricing is one of the most important tax issues for many multinational businesses. Cost sharing adds certainty to a particularly vexing area of transfer pricing—the allocation of income attributable to intangiibl assets. One controversial tax issue threatens the vitality of the cost sharing regulations: the...

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