What Allocation of Income and Deductions Among Taxpayers (Section 482) - Transfer Pricing Methods requires
U.S. Treasury Regulations under Section 482 empower the IRS to reallocate income, deductions, and credits between two or more commonly controlled entities to prevent tax evasion and clearly reflect income. As mandated by § 1.482-1(b), all controlled transactions must adhere to the arm's length standard, meaning they must be priced as if conducted between unrelated parties.
Pillar: Tax & Transfer Pricing · Authority: United States Department of the Treasury, Internal Revenue Service (IRS) · Version: 1.0.0 · Last updated:
Primary source: https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/section-1.482-1
SHA-256 integrity: 47896c00d6dab8e76e59c5a34378a1ea25278527c25c4b258a53d5a050f27f84
Primary Citations — 8 traced to source
- 26 CFR § 1.482-1 - Allocation of income and deductions among taxpayers.
- 26 CFR § 1.482-2 - Determination of taxable income in specific situations.
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