Documents

Imposition of Accuracy-Related Penalty

Federal Register · Uncategorized Document · Feb 2, 1994

adjustment, unless the treatment of that transaction affects the determination of U.S. source income or taxable income that is effectively connected with the conduct of a trade or business within the … Applying section 482, the IRS disallows a deduction for twenty five million dollars of the interest that CFCI paid to CFC2, which results in CFC1's U.S. shareholder having a subpart F inclusion in excess

Intercompany Transfer Pricing Regulations Under Section 482

Federal Register · Uncategorized Document · Jul 8, 1994

Section 1.482-2 also issued under 26 U.S.C. 482. Section 1.482-3 also issued under 26 U.S.C. 482. Section 1.482-4 also issued under 26 U.S.C. 482. … Section 482 and the regulations thereunder apply to all controlled taxpayers, whether the controlled taxpayer files a separate or consolidated U.S. income tax return.

Computation of Combined Taxable Income Under the Profit Split Method When the Possession Product Is a Component Product or an End- Product Form

Federal Register · Uncategorized Document · Jan 12, 1994

The proposed change is intended to simplify the computation of combined taxable income under Q & A. 12 and to eliminate the need to apply section 482 in cases in which a possession product is a component … -- (A) First, to U.S. affiliates (other than tax-exempt affiliates) within the group (as determined under section 482) which derive income with respect to the product produced in whole or in part in

Consolidated Groups and Controlled GroupsIntercompany Transactions and Related Rules

Federal Register · Uncategorized Document · Apr 15, 1994

See also sections 269 (acquisitions to evade or avoid income tax) and 482 (allocations among commonly controlled taxpayers). … First, the $100 of combined income must be divided into foreign and U.S. source income portions.