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Multi-jurisdictional tax issues (Affiliated groups and transfer pricing…
Multi-jurisdictional tax issues
Affiliated groups and transfer pricing
IRS options
Authority of the IRS to make adjustments
Transfer pricing issues
Limited right of a controlled taxpayer to make adjustments
Arm's-length standard
Avoidance of penalties
Section 482
Solely between foreign corps
IRS Distribution/apportionment/allocation
Competent Authority
Advance pricing agreement program
State income tax considerations
State allocation and apportionment of federal taxable income
State income taxes and controlled taxpayers
Federal limitations on a state's right to impose income
Nonresident alien(NRA) withholding
Taxation of foreign entities
Sourcing foreign income
Entity
Calculating foreign tax credit limitation by category
Anti-deferral rules