The Resource Functional analysis is alive and well in Section 482 regulations, Triplett tells ITI Seminar

Functional analysis is alive and well in Section 482 regulations, Triplett tells ITI Seminar

Label
Functional analysis is alive and well in Section 482 regulations, Triplett tells ITI Seminar
Title
Functional analysis is alive and well in Section 482 regulations, Triplett tells ITI Seminar
Creator
Subject
Summary
This article deals with the new proposed regulations on transfer- pricing under section 482. The author points out that in IRS's view, the new regulations have an interpretative character and their intention is to broaden the existing rules. The main change in the regulations is the use of a comparable profit interval to check the validity of transfer prices derived from other pricing methodologies. Issues include the lack of available data to determine comparable prices to formulate the comparable profit interval, a three year averaging concept regarding cost adjustments and the elimination of the current restriction regarding the use of a lower priority method for determining an arm's length consideration in transfers of tangible and intangible goods
Citation source
In: Tax notes international. - Arlington. - Vol. 4 (1992),
http://library.link/vocab/creatorName
Mathews, K
Language note
English
http://library.link/vocab/subjectName
  • functional analysis
  • transfer pricing
  • intangibles
Label
Functional analysis is alive and well in Section 482 regulations, Triplett tells ITI Seminar
Instantiates
Publication
Abbreviated title
TaxNint
Label
Functional analysis is alive and well in Section 482 regulations, Triplett tells ITI Seminar
Publication
Abbreviated title
TaxNint

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