US: Regulations coordinating rules under sections 367, 482

Regulations coordinating rules under sections 367, 482

Temporary regulations (T.D. 9738) published in today’s edition of the Federal Register were issued to clarify the arm’s length standard and the best method rule under the tax law provisions that govern transfer pricing (Code section 482). By cross-reference, proposed regulations (REG-139483-13) were issued relating to the transfer of property—including foreign goodwill and going-concern value—to foreign corporations in nonrecognition transactions under section 367.


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Read a September 2015 report prepared by the KPMG member firm in the United States: Regulations narrow section 367(a) “active trade or business” exception; temporary regulations coordinating section 482 rules

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