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Keywords: commensurate with income standard
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Journal Articles
Journal of the American Taxation Association (2024) 46 (2): 111–122.
Published: 01 September 2024
... satisfies the arm’s-length principle. Nevertheless, the commensurate with income standard allows the U.S. tax authority to revalue the transfer price upward to $1,000,000 in case of the favorable outcome. The taxpayer is not allowed to revalue the transfer price downward to $0 in the case of an unfavorable...
Journal Articles
Journal of the American Taxation Association (2019) 41 (1): 123–136.
Published: 01 March 2019
... reviewers for helpful comments. Editor's note: Accepted by Connie D. Weaver. July 2017 April 2018 2019 intangible property cost-sharing arrangements income shifting transfer pricing commensurate with income standard This study investigates the use of a cost-sharing...