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 certain situations: On a timely filed U.S. income tax return, the taxpayer is reporting the results of a transaction which are different than the actual prices charged, but is doing so to clearly reflect an...