What 26 U.S. Code § 482 - Allocation of income and deductions among taxpayers requires
This regulation authorizes the Secretary of the Treasury to allocate income, deductions, credits, or allowances between related organizations or businesses to prevent tax evasion or clearly reflect income. It specifically requires that income from transfers or licenses of intangible property be commensurate with the income attributable to the intangible under § 482.
Pillar: Tax & Transfer Pricing · Authority: U.S. Congress · Version: 1.0.1 · Last updated:
Primary source: https://www.law.cornell.edu/uscode/text/26/482
SHA-256 integrity: c451e28ca12468881420a2e0c3af836f808d764329b5166d4c2e5102d4f0c970
Primary Citations — 5 traced to source
- 26 U.S. Code § 482 - Allocation of income and deductions among taxpayers
- 26 U.S. Code § 482 - In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
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