The Forgotten Link: "Control" in Section 482

Gazur, Wayne M.

Journal: Northwestern Journal of International Law & Business

Volume: 15

First Page: 1

Year: 1994

Bluebook Citation: 15 NW. J. INT'L L. & BUS. 1 (1994)

Author: Wayne M. Gazur: all 8 publications


Abstract

The foundation of international taxable income allocations between related parties is formed by the imposition of an arm's length standard. The presence of "control" over a person invokes this measure. The author examines the implications of control presented by continuing developments in the global business environment, including the rise of cooperative interfirm arrangements.

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