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Tag Archive for Section 482

Tangible Property – Section 482 and International Financial Centers

Introduction

Corporate structures in global enterprise find the use of conduit offshore corporate entities a requisite to accommodate the anomalies inherent in maximizing efficiencies and cost savings. Common ownership of inter-related corporate structures encounter arms length pricing scrutiny. (See TaxConnections April 24, 2014, Introduction to Section 482 and International Financial Centers.)

Arm’s length standards of Section 482 are applicable to a transfer of tangible property rights in transactions when deemed between controlled entities. When the possession, use or occupancy of tangible property that is owned or leased by one member of a group of Read more

Intangible Property – Section 482 And International Financial Centers

Introduction

Inter-company pricing embraces some basic concepts. Those principles emanate from virtues of corporate structures that have related ownership of entities. The dealings between related entities brings into play arms length standards applicable to related entities. (See TaxConnections, April 24, 2014, Introduction to Section 482 and International Financial Centers) These governing guidelines are promulgated by regulation particularly to conduit entities that provide sales, services, personal property, and intangible property entities that compliment global enterprise of a parent or subsidiary. This writing focuses upon the guidelines that establish the borders of intangible property. Read more

Introduction To Section 482 And International Financial Centers

Introduction

As an introduction to International Financial Centers and the pricing concepts between structures of entities, an integration of international law principles and taxation concepts is desirable. This is the essence and difficulty of understanding Financial Centers Offshore. It requires a melding of international financial law, international civil and criminal law, and international taxation rules. It is the bifurcation of these disciplines that makes International Financial Centers so elusive.

The foundation to a discussion of entity structure concepts is melding the taxation rules peculiar to foreign corporate entities; controlled entity rules, source of income Read more

Advance Pricing Agreements Report Released By IRS

Report Concerning Advance Pricing Agreements (2013)

Highlights excerpted:

In February of 2012, the former APA Program was moved from the Office of Chief Counsel to the Office of Transfer Pricing Operations, Large Business and International Division of the IRS (TPO) and combined with the United States Competent Authority (USCA) staff responsible for transfer pricing cases, thereby forming the Advance Pricing and Mutual Agreement (APMA) Program.  During the last quarter of 2013, new proposed revenue procedures governing APA applications and MAP applications were released for public comment in Notice 2013-792013-50 I.R.B. 653, and Notice 2013-78, 2013-50 I.R.B. 633, Read more

Legal Risks of Offshore Financial Centers

TaxConnections Blogger Posts
Generally

Offshore Financial Centers and Financial Havens require an appreciation of the transactional risks accompanying their benefits. Even the simplest transactions give rise to complex legal relationships and draw upon a number of legal disciplines.

It is essential in dealing with this aspect of using Offshore Financial Centers to develop a method identifying the various relationships created and the underlying risk associated with each part of the financial transaction. To accomplish this, a technique can be used in evaluating transactions to determine the means that can be employed to reduce or eliminate each risk. The identification of risks can be crucial because it also serves to broaden Read more