{"abstract":"This document contains proposed regulations that provide guidance regarding the treatment of controlled services transactions under section 482 and the allocation of income from intangibles, in particular with respect to contributions by a controlled party to the value of an intangible that is owned by another controlled party. These proposed regulations potentially affect controlled taxpayers within the meaning of section 482. The proposed regulations provide updated guidance that is necessary to reflect economic and legal developments since the issuance of the current guidance. This document also provides a notice of public hearing on these proposed regulations.","action":"Notice of proposed rulemaking and notice of public hearing.","agencies":[{"raw_name":"DEPARTMENT OF THE TREASURY","name":"Treasury Department","id":497,"url":"https://www.federalregister.gov/agencies/treasury-department","json_url":"https://www.federalregister.gov/api/v1/agencies/497","parent_id":null,"slug":"treasury-department"},{"raw_name":"Internal Revenue Service","name":"Internal Revenue Service","id":254,"url":"https://www.federalregister.gov/agencies/internal-revenue-service","json_url":"https://www.federalregister.gov/api/v1/agencies/254","parent_id":497,"slug":"internal-revenue-service"}],"body_html_url":"https://www.federalregister.gov/documents/full_text/html/2003/09/10/03-22550.html","cfr_references":[{"chapter":null,"citation_url":null,"part":1,"title":26},{"chapter":null,"citation_url":null,"part":31,"title":26}],"citation":"68 FR 53448","comment_url":null,"comments_close_on":"2003-12-09","correction_of":null,"corrections":[],"dates":"Written or electronic comments must be received December 9, 2003. Outlines of topics to be discussed at the public hearing scheduled for January 14, 2004, at 10 a.m. must be received by December 23, 2003.","disposition_notes":null,"docket_ids":["REG-146893-02, REG-115037-00"],"dockets":[],"document_number":"03-22550","effective_on":null,"end_page":53482,"executive_order_notes":null,"executive_order_number":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2003/09/10/03-22550.xml","html_url":"https://www.federalregister.gov/documents/2003/09/10/03-22550/treatment-of-services-under-section-482-allocation-of-income-and-deductions-from-intangibles","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/03-22550?publication_date=2003-09-10","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2003-09-10/03-22550/mods.xml","not_received_for_publication":null,"page_length":35,"page_views":{"count":608,"last_updated":"2026-10-25 04:15:05 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2003-09-10/pdf/03-22550.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":null,"publication_date":"2003-09-10","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2003/09/10/03-22550.txt","regulation_id_number_info":{"1545-AY38":{"issue":"200404","html_url":"https://www.federalregister.gov/regulations/1545-AY38/allocation-of-income-and-deductions-from-intangibles","title":"Allocation of Income and Deductions from Intangibles","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=200404&RIN=1545-AY38&operation=OPERATION_EXPORT_XML","priority_category":"Substantive, Nonsignificant"},"1545-BB31":{"issue":"200904","html_url":"https://www.federalregister.gov/regulations/1545-BB31/treatment-of-services-under-section-482","title":"Treatment of Services Under Section 482","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=200904&RIN=1545-BB31&operation=OPERATION_EXPORT_XML","priority_category":"Substantive, Nonsignificant"}},"regulation_id_numbers":["1545-AY38","1545-BB31"],"regulations_dot_gov_info":{},"regulations_dot_gov_url":null,"significant":false,"signing_date":null,"start_page":53448,"subtype":null,"title":"Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangibles","toc_doc":"Section 482; treatment of services and allocation of income and deductions from intangibles","toc_subject":"Income taxes, etc.:","topics":["Employment taxes","Income taxes","Penalties","Pensions","Railroad retirement","Reporting and recordkeeping requirements","Social security","Unemployment compensation"],"type":"Proposed Rule","volume":68}