The Tax Adviser to publish paper by Ilitch School professors, student

Mike Ilitch School of Business accounting professors B. Anthony Billings and William Volz, along with their student research assistant Kyungjin (KJ) Kim, have had their paper entitled “New Developments in Foreign Transfers of Intangible Property" accepted for publication in the March 2017 issue of The Tax Adviser.

This journal is published by the American Institute of Certified Public Accountants (AICPA), has wide readership among tax practitioners, and is listed as a B on the Ilitch School's journal list. 

"It's great to have a student included as a co-author," said Myles Stern, chair of the Ilitch School's accounting department. "It's an important part of our mission as a research-oriented business school to involve students in meaningful ways in faculty research."


This article updates Certified Public Accountants (CPA) about the changes in tax treatment of outbound transfers of goodwill or going concern value so that they may help their clients in planning outbound transfers of these intangible assets. Several judicial decisions, including the Veritas Software Corp. case, have raised questions about whether the definition of intangible property covers foreign goodwill, going concern value, or workforce in place within the meaning of the statutory language of Internal Revenue Code (IRC) Sec. 367(d). The article also reviews the U.S. Treasury Department and the Internal Revenue Service (IRS) regulations under IRC Sec. 367 limiting the scope of intangible property that is subject to tax-deferred treatment under IRC Sec. 367(d).

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