The article examines the problem of contributed zero-basis intangibles in light of the IRS’s inadvertent disclosure of a transaction structured by Bristol-Myers Squibb to shift billions of dollars of built-in gain to a related foreign partner

In cooperative networks firms appropriate value through bargaining over the economic benefits generated from successful execution of joint tasks and through internalizing the knowledge of partners. Consequently, acquisition and protection of knowledge are the key issues for collaborating...