Temporary Regs. Under Sec. 482 Coordinate Transfer-Pricing Rules with Other Code
The temporary regulations provide that the arm’s-length standard of Sec. 482 applies to all controlled transactions without regard to the form or character of the transactions, and they are particularly concerned with tax-favored transfers of assets outside the U.S.Â Jay L. Camillo, M.A. (international relations), Atlanta, and Kenneth P. Christman Jr., J.D., Washington, explain.
To read the full article in The Tax Adviser, click: Temporary Regs. Under Sec. 482 Coordinate Transfer-Pricing Rules with Other Code.