Transfer pricing : the code, the regulations and selected case law /
" ... is the foundation of the Transfer Pricing Portfolio Series ... The first part of this Portfolio discusses the evolution of [section] 482 from its beginnings in the early 20th century to the current iteration and the adoption in 1986 of the commensurate-with-income standard for transfers o...
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Main Author: | |
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Corporate Author: | |
Other Authors: | , |
Format: | Online |
Language: | English |
Published: |
Arlington, VA :
Tax Management Inc.,
[©1997]-
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Series: | Tax management portfolios ;
886-2nd |
Subjects: | |
Online Access: | https://www.bloomberglaw.com/product/tax/citation/tm%20886 |
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Summary: | " ... is the foundation of the Transfer Pricing Portfolio Series ... The first part of this Portfolio discusses the evolution of [section] 482 from its beginnings in the early 20th century to the current iteration and the adoption in 1986 of the commensurate-with-income standard for transfers of intangible property ... The second part of the Portfolio analyzes the [section] 482 regulations in depth, focusing on the 1994 regulations (as amended to date), but including discussion of prior regulations to facilitate understanding of current concepts and methods ... The final part of the Portfolio traces the development of judicial approaches to the problem of comparability through an analysis of significant cases decided under [section] 482." |
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Item Description: | Published: Washington, D.C., 1997-2007 |
Publication Frequency: | Updated irregularly |
Format: | Mode of access: World Wide Web |
Bibliography: | Includes bibliographical references |