In a transfer of IP, if a tax mechanism is available to reduce or eliminate capital gains tax on the transfer, the agreement will be required to contain a price adjustment clause. This clause states that the parties intend the IP to be valued at fair market value, but that if a tax authority or the parties later determine that the fair market value is different from that which is used at the time of the transfer, the agreement will be automatically amended to use the revised value, as of the date of the agreement. The clause also states that any subsequent value must be approved by the tax authorities, and that the parties will file all necessary documents to give effect to the section. This permits a later amendment to the value that will be effective retroactively to the original date and under the original form filed with the tax authority.