In the structural model, firms' pass-through of foreign cost shocks is on average 29 percentage points lower in arm's-length transactions
than in multinational transactions because the higher markups from a double optimization along the distribution chain create more opportunity for markup adjustment following a shock.
The personal services safe harbor requires that the aggregate compensation paid for the services be set in advance and consistent with fair market value in arm's-length transactions
4 is flawed and should be abandoned, the overbreadth of the proposed changes can be addressed by eliminating the proposed amendments to section 68, especially in arm's-length transactions
where the parties to the agreement make no initial allocation to a "restrictive covenant.
Even though section 1041 nullified Davis on the recognition of gain requirement, the fact that transfers pursuant to a divorce are arm's-length transactions
Related-party activities should generally be viewed with skepticism because they often fail to constitute arm's-length transactions
,'' the newsletter said.
1041 nullified the Davis holding that a stock transfer between spouses was taxable, Davis still stands for the proposition that transfers pursuant to divorce are arm's-length transactions
and that the properties exchanged are of equal value.
The intent is to ensure that only gains or losses on arm's-length transactions
are recognized," says Meyer.
The price at which similar interests have changed hands in arm's-length transactions
11) This represents an administrative reversal of the Bausch & Lomb decision(12)(where actual arm's-length transactions
were used) and is arguably inconsistent with the Canadian interpretation of the arm's-length standard.
This provision, one of the most powerful in the code, is aimed at forcing related entities to engage in arm's-length transactions
, particularly with respect to transfer-pricing policies.
Sales and exchanges of property between insiders and pension plans were designated prohibited transactions to ensure the safety of the pension plan system, by eliminating the possibility that such sales and exchanges may not be arm's-length transactions
In this regard, the IRS said section 4975 was intended to supplement the rules of prior law that permitted arm's-length transactions
between the employer and its tax-qualified retirement plan to ensure that the value of these types of transactions (which have a great potential for abuse) would not have to be reviewed.