To determine whether employees are not dealing at
arm's length with their employers, the CRA considers the circumstances of their employment.
We overcome these conceptual and methodological deficiencies by examining how cultural distance influences aggregate
arm's length exports, while simultaneously considering its impact on aggregate
arm's length affiliate sales.
482-1 expressly requires that "the standard to be applied in every case is that of a taxpayer dealing at
arm's length with an uncontrolled taxpayer.
Since the transfer was at
arm's length, there were no additional tax consequences to the husband when his ex-wife later exercised the options.
Taxpayers can avoid penalties for transfer pricing adjustments by complying with the standard, reporting
arm's length results on their income tax returns, contemporaneously documenting their transfer pricing using methods described in the section 482 regulations and providing that documentation to the IRS upon request.
Whatever the contract's term, it needs to be negotiated at
arm's length with an unrelated party at market rates.
Arm's length finders' fees of 400,000 common shares and U.
It generally includes other foreign affiliates, any person who does not deal at
arm's length with the taxpayer, and certain trusts and partnerships.
In any case, Chelsea should keep the whole enterprise at
arm's length.
The proposals also call for a new 100 percent excise tax to ensure:
arm's length pricing for services provided to the REIT's tenants (to ensure that tenants are not paying the REIT higher rent in exchange for a discount on services that would be taxable income to the service subsidiary); and
arm's length allocations for shared expenses between the REIT and its taxable Subsidiary.
Although the stock was sold to an unrelated corporation, the court concluded the transaction was not at
arm's length because the purchaser was compelled to buy.
Prior to completion of the Acquisition Bema is not a Non
Arm's Length to the Company.
