Temporary Regs. Under Sec. 482 Coordinate Transfer-Pricing Rules with Other Code
Regulations Clarify Arm's-Length Standard for Transfer-Pricing Rules 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. Jay L. Camillo, M.A. (international relations), Atlanta, and Kenneth P. C ...
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