Section 482

US Department of Treasury regulations governing transfer prices.

Section 482

A section of the U.S. Tax Code allowing the IRS to allocate assets, income, deductions, and so forth between different branches of the same company or between different companies controlled by the same interests. That is, the IRS may treat these branches or companies as one branch or one company for tax purposes. This section exists to reduce tax evasion by preventing a company from hiding its taxable income in a subsidiary or a separate company.

Mentioned in ?

transfer price

References in periodicals archive ?

This issue had previously been decided in taxpayers' favor pursuant to prior regulations under Section 482.

Altera deconstructed: a nuanced alteration in tax law; Tax Court's unanimous opinion deals with unusual regulatory situation

in connection with section 482 adjustments are treated as indebtedness for purposes of section 965(b)(3).

BMC software: a hidden holding on the weight afforded to published guidance

Budihal said: " I am of the opinion that it is not a case to invoke section 482 CrPC to quash the proceedings.

HC dismisses Gowda son's rape case plea

The resolution phase envisions the Examination team working with the taxpayer to hopefully reach an agreed-upon position on any proposed Section 482 adjustments.

What does the new IRS transfer pricing audit road map mean for multinationals?

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.

Complying with expanding state transfer pricing rules: strategies for multistate corporations

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.

Yeddyurappa FIR quashing challenged in SC

section 482 in the case of transfers to a foreign corporation.

Deterring transfer pricing abuse: changing incentives as a practical alternative to a global tax regime

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.

Re-thinking first principles of transfer pricing rules

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.

P&G appeals deduction denial

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 [8].

Foreign Sales Corporations, 2000

In the United States, the Internal Revenue Service (IRS) can utilize Internal Revenue Code (IRC) Section 482 to attack such tax avoidance strategies.

Utilizing tax havens in income tax, estate and asset protection planning

Only by invoking section 482 could mining claims on national forests gain extralateral and surface rights.

The 1872 mining law and the 20th century collide: a rediscovery of limits on mining rights in wilderness areas and national forests