Raamp;D and patent va lue also were considered, while in another aspect of the case (involving CUP for 1973), market level, ... Guide, aquot;Economic Aspects of As 482aquot;); capabilities and abilities in the areas of management, marketing and service: ... The IRS Manual states that the examining IRS agent must involve an economist in a As 482 case where the adjustment is $5 million or more. ... 608 F.2d 445 (Ct. CI.
|Title||:||Transfer pricing and the foreign owned corporation|
|Author||:||Bobbe Hirsh, Practising Law Institute|