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
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.
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.