482-2(b) cost safe harbor and to bring the existing rules more in line with the
arms-length standard.
The basic idea is that the IP is licensed to the various foreign operating companies ("OPcos") in exchange for an
arms-length royalty.
Each of Gateshead Council's 26,442 tenants and leaseholders will receive a questionnaire this week, asking if they want to support the setting up of an
arms-length group to manage council housing in the future.
Moreover, to the extent the guidelines require the disclosure and measurement of returns for members that are not a party to a controlled transaction that is being tested for comparability under the
arms-length principle, we question whether the documentation requirement is enforceable under the Canadian, U.
An owner is permitted to object to the proposed sale on several grounds including a claim that the price is too high or that the proposed sale is not a bona fide
arms-length transaction.
tax treaty; (2) the related party is not a controlled foreign corporation; and (3) the amounts are also deductive for Federal income tax purposes and arranged through
arms-length pricing.
At many companies,
arms-length relationships are in place and parent companies can repatriate only dividends from overseas subsidiaries, says Ken Parkinson, a partner at Treasury Information Services in Hopewell, N.
Taxpayers do not purposefully set miles prices at a level higher than the
arms-length price, or their cost of goods at a level below that price.
The federal and provincial finance ministers, in their role as stewards of the Plan, produced a carefully crafted governance framework that balances accountability with an ability to operate at
arms-length from government.
16 (1994), that, in determining tax consequences, it would follow the express allocation of claims in a written settlement agreement if the parties reached the settlement as a result of "bona fide,
arms-length, adversarial negotiations.
Arms-Length Pricing: Some Economic Perspectives, 54 Tax Notes 731, 732, (1992) ("formula allocation could be a viable alternative only with a very radical change in worldwide tax procedures.
By definition these aren't
arms-length deals in an open marketplace, and they raise tough questions.
