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IRS Releases Practice Units on Common Ownership and Control for Inbound and Outbound Transactions

|Approved Changes|United States
United States

The U.S. IRS has released two international practice units concerning common ownership and control under IRC Section 482 (transfer pricing), including Common Ownership or Control Under IRC 482 - Inbound, and Common Ownership or Control Under IRC 482 - Outbound. Each practice unit covers the general determination of common ownership and control, with a focus on factors of control, including vo…

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