Base erosion payments would not include payments for services from related parties if the service payments are eligible for the services cost method (SCM) under Section 482
of the Code without application of the business judgment rule.
in connection with section 482
adjustments are treated as indebtedness for purposes of section 965(b)(3)." Section 10.06 contains only this sentence, and the issue is not discussed in any other part of Notice 2005-64.
Budihal said: " I am of the opinion that it is not a case to invoke section 482
CrPC to quash the proceedings.
The resolution phase envisions the Examination team working with the taxpayer to hopefully reach an agreed-upon position on any proposed Section 482
Many states generally follow the transfer-pricing methodology under Internal Revenue Code (IRC) section 482
by enacting laws that adopt IRC section 482
or by granting analogous authority to their revenue commissioners (Cara Griffith, "States' No-Holds-Barred Approach to Auditing Transfer Pricing Arrangements," BNA Tax Analysts Practice Notes, Feb.
The petition has said that the high court in exercise of its powers under Section 482
of CrPC has grossly erred in quashing the FIR on ground of denial of opportunity as FIR requires only prima facie material to commence investigation which is very much on record and has been completely ignored by the high court.
in the case of transfers to a foreign corporation.
The Commissioner, a state-appointed official, has authority to reformulate a company's consolidated financial statements to make certain that they clearly reflect "the income of any such trade or businesses." Current section 482
of the Tax Code "authorizes the IRS to adjust the income, deductions, credits, or allowances of commonly controlled taxpayers to prevent the evasion of taxes or to clearly reflect their income." (14) Section 482
provides that prices charged by one affiliate to another "yield results that are consistent with the results that would have been realised if uncontrolled taxpayers had engaged in the same transaction.
In its appeal brief before the Sixth Circuit, P&G argued that the district court's summa17 judgment was incorrect because it did not consider whether the IRS correctly assessed tax according to the Service's arm's-length position under section 482
, among other reasons.
The 1.83 percent of gross receipts method, the 23 percent of combined taxable income method, and the marginal costing method are referred to as "administrative" pricing methods, while the Internal Revenue Code section 482
method is the "nonadministrative" pricing method .
In the United States, the Internal Revenue Service (IRS) can utilize Internal Revenue Code (IRC) Section 482
to attack such tax avoidance strategies.
Only by invoking section 482
could mining claims on national forests gain extralateral and surface rights.