Section 482 Allocations: Judicial Decisions and IRS Practice (Portfolio 553)

Description

Bloomberg Tax Portfolio, Section 482 Allocations: Judicial Decisions and IRS Practice No. 553, examines judicial decisions and IRS practice involving the interpretation and application of §482 and the regulations thereunder to transactions between U.S. controlled taxpayers.

Table of Contents

I. Introduction
II. Some Problems of Interpretation under the Statute Addressed in Judicial Decisions and IRS Practice
III. Judicial Decisions and IRS Practice Interpreting the Arm’s-Length Standard in the Regulations
IV. Judicial Decisions and IRS Practice Involving the Relationship Between Section 482 and Traditional Judicial Anti-Tax Avoidance Doctrines
V. Judicial Decisions and IRS Practice Addressing the Burden of Proof in § 482 Cases
VI. Judicial Decisions and IRS Practice Involving Transfers of Tangible Property
VII. Judicial Decisions and IRS Practice Involving the Use of Tangible Property
VIII. Judicial Decisions and IRS Practice Involving the Performance of Services
IX. Judicial Decisions and IRS Practice Involving Loans or Advances
X. Judicial Decisions and IRS Practice Involving the Transfer of Intangibles
XI. Judicial Decisions and IRS Practice Involving the Comparable Profits Method
XII. Judicial Decisions and IRS Practice Applying Profit Split Methods
XIII. Judicial Decisions and IRS Practice Involving Collateral Adjustments
XIV. Judicial Decisions and IRS Practice Involving Setoffs
XV. Judicial Decisions and IRS Practice Involving the Effect of Legal Restrictions
XVI. Judicial Decisions and IRS Practice Involving the Relationship Between § 482 and Nonrecognition Transactions
XVII. Judicial Decisions and IRS Practice Involving Cost Sharing Arrangements
XVIII. Judicial Decisions and IRS Practice Involving Penalties