US IRS Issues Practice Unit on Taxpayer’s Affirmative Use of IRC 482 for Transfer Pricing Purposes
On 12 May 2016, the U.S. IRS publishes an international practice unit on a taxpayer's affirmative use of IRC 482. According to the practice unit, IRC 482 may generally only be used by the IRS to make allocations to ensure that taxpayers clearly reflect income attributable to controlled transactions and to prevent the avoidance of taxes. However, taxpayers are allowed to invoke IRC 482 under ce…
Continue Reading