Conclusions and Policy Recommendations
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KeywordsPolicy Recommendation Intangible Asset Corporate Taxation Transfer Price Multinational Firm
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- 6.In Newark Morning Ledger Company v. U.S., for example, the customer-based intangibles at issue—“paid subscribers”—were valued via the income approach at $67.8 million; the IRS, employing a replacement cost method, put their value at $3 million. (If this $3 million accurately represents replacement cost, it is very difficult to argue that a willing buyer would pay over twenty times this amount for pre-existing subscribers.)Google Scholar
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