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Under the proposal advocated, the Platinum chip would be recognized as an R & D intangible, thus triggering the first sourcing method and allocating an annual income of $500 million, $350 million, and $150 million to USPr, IsSub, and IrSub, respectively.
After the R & D intangible was developed (seemingly by USPr), (169) if transferred to BrSub, it would be subjected to the commensurate-with-income standard and thus require periodic adjustments in accordance with the income derived from it.
USPr and IrSub would qualify as participants because of their distribution centers (and manufacturing facilities in the case of IrSub).
Assuming that USPr and IrSub distribution activities accounted for 70% and 30% of the sales' gross profits, respectively, then the share of each jurisdiction in the income derived from the "Letni within" trademark would be similar to its share in the sales' gross profit.
Every time a transaction is made by USPr, IsSub, or IrSub, its attributes are immediately transferred (electronically) to BrSub where the data are preserved and managed.
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