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General Provisions of Section 482
Performance of Personal Services for a related entity
Use of Tangible Property
3 other sections not shown
account receivable agreement amount applied arm's length charge arm's length price basis benefit carryback considered controlled entities controlled foreign entity controlled sale controlling taxpayer costs and risks costs or deductions determining distributor district director dividend domestic earnings and profits example expenses foreign corporation foreign subsidiary foreign tax credit gross income gross profit percentage group of controlled intangible assets intangible property intercompany charges interest island affiliate lnternal Revenue Code lnternal Revenue Service mainland affiliate manufacturing mark-up percentage ment offset paid paragraph payment percent Puerto Puerto Rico reflect an arm's related entities related parties resale price method reseller respect Revenue Procedure 64-54 rules section 482 allocation seller sells services rendered similar sold subdivision subparagraph tangible property tax authorities Tax Treaty taxable income tion trade or business transactions transfer U. S. parent company uncon United States controlling unrelated parties West Germany WHTC