On 14 september 2015 the treasury department and irs issued treasury decision 9738 which contained temporary regulations under section 482 clarifying the application of the arms length standard when multiple code sections eg sections 482 and 367 apply the temporary regulations apply to tax . On sept 14 2015 the treasury department and the irs issued td 9738 which contained temporary regulations under sec 482 clarifying the application of the arms length standard when multiple code sections eg secs 482 and 367 apply the temporary regulations apply to tax years ending on or after sept 14 2015. Concomitantly with the issuance of the temporary and proposed section 482 regulations the irs issued proposed regulations under sections 6662e and 6662h of the code relating to the imposition of the accuracy related penalty for substantial and gross valuation misstatements attributable to section 482 allocations. Td 9738 sept 16 2015 temporary regulations under section 482 for coverage of the proposed and temporary regulations see global transfer pricing alert 2015 015 dated september 17 2015 for information on the other international tax implications of these regulations including the foreign goodwill and going concern rules see united . Omnibus reconciliation act of 1990 report on the application and administration of section 482 april 1992 1992 report1 1for a prior corporate income tax gap estimate see estimates of the income tax gap among foreign controlled domestic corporations department of the treasury internal revenue service compliance research division june 8
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