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Recommendations Submitted by Taxpayers and Practitioners
Rev Proc 9122Poss1ble
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482 regulations advance pricing agreement affiliate agreement allocation amount analysis apply appropriate argued arm's length consideration arm's length price arm's length standard audit B&L Ireland BALRM Bausch & Lomb Commissioner comparable uncontrolled competent authority relief contract manufacturing cost sharing arrangement Darvon determined discussed Eli Lilly filed foreign competent authority foreign related party functions income inexact comparables intangible property intercompany pricing Internal Revenue Service involved issue license Lilly P.R. Lilly U.S. location savings manufacturing intangibles marketing Paccar payment penalty percent possessions subsidiary Proc profit split Puerto Rico rate of return reallocation records rejected reporting corporation respect revenue procedure risk rules Searle P.R. Searle U.S. section 351 transfer section 482 Service's STPR STUS STUS's substantial summons Sundstrand SunPac Tax Court tax treaties taxable taxpayer transfer price transfers of intangibles Treas treaty U.S. competent authority U.S. subsidiary United unrelated parties White Paper