On 14 September 2015, the U.S. Department of Treasury and IRS issued temporary regulations (T.D. 9738) that clarify the coordination of the application of the arm's length standard and the best method rule under section 482 of the Internal Revenue Code (Code) in conjunction with other provisions of the Code. The need for clarification is due to the fact that, while the determination of arm's length prices for controlled transactions is governed by section 482, the tax treatment of controlled transactions is also governed by other Code and regulatory rules applicable to both controlled and uncontrolled transactions. In particular, transfers...