Extract to table

Specifically, IRC § 367(d)(1) provides that if a United States person transfers intangible property (as defined in § 367(d)(4), which references the definition in § 936(h)(3)(B)) to a foreign corporation in an exchange described in §§ 332, 351, 354, 355, 356, or 361, the transferor shall be treated as having sold the intangible property in exchange for annual payments contingent on the productivity, use, or disposition of such property

99-514, § 1231(e), and reflects Congress's view that the compensation for intangible property transfers — whether in the form of actual or deemed payments — must bear a reasonable relationship to the actual economic returns generated by the intangible

Under these principles, the IRS must ensure that an adjustment under § 482 that increases one party's income results in a corresponding decrease in the other party's income