In the case of any transfer (or license) of intangible property (within the meaning of section 367 (d) (4)), the income with respect to such transfer or license shall be commensurate with the …

- The Secretary of the Treasury or his delegate shall conduct a study of the application and administration of section 482 of the Internal Revenue Code of 1986.

al -- (1) Purpose and scope. The purpose of section 482 is to ensure that taxpayers clearly reflect income attributable to controlled transactions, and t prevent the avoidance of taxes with …

Jan 1, 2024 · In the case of any transfer (or license) of intangible property (within the meaning of section 367 (d) (4)), the income with respect to such transfer or license shall be commensurate …

Allocation of income and deductions among taxpayers.

Find out who that 482 phone number is registered to. Our free reverse phone lookup allows you to search records associated with a landline or cell phone number to help quickly identify who’s …

In the case of any transfer (or license) of intangible property (within the meaning of section 367 (d) (4)), the income with respect to such transfer or license shall be commensurate with the …

Dec 11, 2025 · Review Internal Revenue Code (IRC) Section 482—allocation of income and deductions among taxpayers. Read proposed regulations and the full-text on Tax Notes.

Searchable text of the 26 USC 482 - Allocation of income and deductions among taxpayers (US Code), including Notes, Amendments, and Table of Authorities

Section 482 places a controlled taxpayer on a tax parity with an uncontrolled taxpayer by determining the true taxable income of the controlled taxpayer. This section sets forth general …