The Profit-Split Method: A Commentary on the Nulon Example

July 3, 2023

The Profit-Split Method: A Commentary on the Nulon Example

In this third article of the profit split method (PSM) series, Guy Sanschagrin and Doug Schwerdt explain the Nulon example provided by the U.S. Treasury Regulations, which illustrates the IRS’s general approach to applying the Residual PSM. Credit to Kash Mansori for his contributions to this article.

For reference, the article was first published in Tax Notes International, Volume 111, July 3, 2023, page 7.

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