In this CLE course you will learn the statutory and regulatory history of how the U.S. has priced controlled transactions between controlled taxpayers that involve intangible property. As part of this history we will explore the new provisions of the Tax Cut & Jobs Act, that affect intangibles and transfer pricing. We will analyze the concepts around intangible property that inform both U.S. transfer pricing between taxpayers and the Internal Revenue Service, as well as transfer pricing between the Internal Revenue Service and the governments with whom the U.S. has entered tax treaties. These concepts include but are not limited to: the commensurate with income principle, aggregation, realistic alternatives, and cost sharing, and Pillar 1 and Pillar 2 of the OECDs proposals.