Section 482 authorizes the IRS to allocate income, deductions, credits, and other tax items among controlled taxpayers to prevent tax evasion and clearly reflect income.
US authority
US Treasury Regulations § 1.482
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- Code
- 26 CFR
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26 CFR § 1.4829
§ 1.482-1
Allocation of income and deductions among taxpayers
In general—(1) Purpose and scope. The purpose of section 482 is to ensure that taxpayers clearly reflect income attributable to controlled transactions and to prevent the avoidance of taxes with...
10 sections · 194 ¶§ 1.482-2
Determination of taxable income in specific situations
Loans or advances—(1) Interest on bona fide indebtedness—(i) In general. Where one member of a group of controlled entities makes a loan or advance directly or indirectly to, or otherwise becomes a...
6 sections · 69 ¶- (a) Loans or advances
- (b) Alleged indebtedness.
- (c) Exception for trade or business of debtor member located outside the United States.
- (d) Exception for regular trade practice of creditor member or others in creditor's industry.
- (e) Exception for property purchased for resale in a foreign country—(1) General rule.
- (f) Effective/applicability date
§ 1.482-3
Methods to determine taxable income in connection with a transfer of tangible property
In general. The arm's length amount charged in a controlled transfer of tangible property must be determined under one of the six methods listed in this paragraph (a). Each of the methods must be...
6 sections · 87 ¶§ 1.482-4
Methods to determine taxable income in connection with a transfer of intangible property
In general. The arm's length amount charged in a controlled transfer of intangible property must be determined under one of the four methods listed in this paragraph (a). Each of the methods must be...
8 sections · 88 ¶- (a) In general.
- (b) Definition of intangible.
- (c) Comparable uncontrolled transaction method
- (d) Unspecified methods
- (e) Coordination with tangible property rules.
- (f) Special rules for transfers of intangible property
- (g) Coordination with rules governing cost sharing arrangements.
- (h) Effective/applicability date
§ 1.482-5
Comparable profits method
In general. The comparable profits method evaluates whether the amount charged in a controlled transaction is arm's length based on objective measures of profitability (profit level indicators)...
5 sections · 40 ¶§ 1.482-6
Profit split method
In general. The profit split method evaluates whether the allocation of the combined operating profit or loss attributable to one or more controlled transactions is arm's length by reference to the...
4 sections · 27 ¶§ 1.482-7
Methods to determine taxable income in connection with a cost sharing arrangement
In general. The arm's length amount charged in a controlled transaction reasonably anticipated to contribute to developing intangibles pursuant to a cost sharing arrangement (CSA), as described in...
13 sections · 432 ¶- (a) In general.
- (b) Cost sharing arrangement.
- (c) Platform contributions
- (d) Intangible development costs
- (e) Reasonably anticipated benefits share
- (f) Changes in participation under a CSA
- (g) Supplemental guidance on methods applicable to PCTs
- (h) Form of payment rules
- (i) Allocations by the Commissioner in connection with a CSA
- (j) Definitions and special rules
- (k) CSA administrative requirements.
- (l) Effective/applicability dates.
- (m) Transition rule
§ 1.482-8
Examples of the best method rule
Introduction. In accordance with the best method rule of § 1.482-1(c), a method may be applied in a particular case only if the comparability, quality of data, and reliability of assumptions under...
3 sections · 22 ¶§ 1.482-9
Methods to determine taxable income in connection with a controlled services transaction
In general. The arm's length amount charged in a controlled services transaction must be determined under one of the methods provided for in this section. Each method must be applied in accordance...
14 sections · 255 ¶- (a) In general.
- (b) Services cost method
- (c) Documentation.
- (d) Gross services margin method
- (e) Cost of services plus method
- (f) Comparable profits method
- (g) Profit split method
- (h) Unspecified methods.
- (i) Contingent-payment contractual terms for services
- (j) Total services costs.
- (k) Allocation of costs
- (l) Controlled services transaction
- (m) Coordination with transfer pricing rules for other transactions
- (n) Effective/applicability date
Source: Electronic Code of Federal Regulations. View on eCFR
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