In some situations, relatives can be considered to be at arm's length
if the circumstances of their employment are substantially similar to those that would exist if they were dealing at arm's length
Analyzing a panel dataset of US foreign affiliate sales and US exports to unaffiliated parties, we find that cultural distance negatively affects arm's length
affiliate sales but positively affects arm's length
Similar to the section 482 regulations, the Organization for Economic Cooperation and Development (OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrators ("OECD guidelines") endorse the arm's length
principle as the international standard for the evaluation of intra-group pricing.
Bush pere may have even blanched at seeing the unsuccessful oilman in the baseball business, greeting fans in the stands but reportedly at arm's length
from crucial business decisions.
This case serves as a reminder to CPAs that they must base all valuations on the price that would be obtained in an arm's length
transaction between a willing buyer and a willing seller with neither party forced to participate.
Prior to completion of the Acquisition Wolfden is not a Non Arm's Length
to the Company.
True taxable income is determined using the standard of a taxpayer dealing at arm's length
with an unrelated party.
If any one or more of the tracked properties are not owned by the NRE, the only exception from tracking entity status is if it is reasonable to conclude that any investment property owned by the NRE (or an entity that does not deal at arm's length
with the NRE), or substituted property, could be used to satisfy the right to receive the tracked property payment.
The new regulations' guiding principle is that transactions between related entities should have the same results as those between two unrelated entities dealing at arm's length
It is proposed that $450,000 worth of arm's length
debt will be settled for Units on the same terms as described above.
In determining true taxable income, "the standard to be applied in every case is that of a taxpayer dealing at arm's length
with an uncontrolled taxpayer" (Regs.
Section 482 of the Internal Revenue Code requires that the payment for intangibles be arm's length
and commensurate with income.
The Vendor is at arm's length
to the Corporation, Subsidiary Trustand the REIT.
The onus is on the tax authority to prove whether the TP is at arm's length
to establish transfer prices in accordance with the arm's length