Inter-company pricing rules
United States Code
Citation analytics
How this statute sits in the citation network, derived from CiteLaw's graph of published opinions.
Frequently CitedTop 12% most-cited · cited by 17 decisions
17
Citing decisions
6+
Courts citing
Citations by decade
3
12
1
1
1980s1990s2000s2020s
Courts citing this statute
Most recently cited by10
- 2020Rivera Casanova v. United States S.D. Cal.
- 2003Boeing Co. v. United States U.S.
- 1999Computervision Corp. v. Commissioner 1st Cir.
- 1999Dresser Industries, Inc. v. United States N.D. Tex.
- 1997Bowater, Inc. & Subsidiaries v. Commissioner 2d Cir.
- 1996General Motors Corp. v. Arizona Department of Revenue Ariz. Ct. App.
- 1995International Paper Co. v. United States Fed. Cl.
- 1994Archer-Daniels-Midland Company v. United States 7th Cir.
- 1994Archer-Daniels-Midland Co. v. United States 7th Cir.
- 1993Dow Corning Corp. v. United States Fed. Cir.
Counts reflect decisions in the CiteLaw corpus and may lag very recent opinions.
Text
4 percent of the qualified export receipts on the sale of such property by the DISC plus 10 percent of the export promotion expenses of such DISC attributable to such receipts, 50 percent of the combined taxable income of such DISC and such person which is attributable to the qualified export receipts on such property derived as the result of a sale by the DISC plus 10 percent of the export promotion expenses of such DISC attributable to such receipts, or taxable income based upon the sale price actually charged (but subject to the rules provided in section 482). rules which are consistent with the rules set forth in subsection (a) for the application of this section in the case of commissions, rentals, and other income, and rules for the allocation of expenditures in computing combined taxable income under subsection (a)(2) in those cases where a DISC is seeking to establish or maintain a market for export property. For purposes of this section, the term “export promotion expenses” means those expenses incurred to advance the distribution or sale of export property for use, consumption, or distribution outside of the United States, but does not include income taxes. Such expenses shall also include freight expenses to the extent of 50 percent of the cost of shipping export property aboard airplanes owned and operated by United States persons or ships documented under the laws of the United States in those cases where law or regulations does not require that such property be shipped aboard such airplanes or ships. In the case of a sale of export property to a DISC by a person described in section 482, the taxable income of such DISC and such person shall be based upon a transfer price which would allow such DISC to derive taxable income attributable to such sale (regardless of the sales price actually charged) in an amount which does not exceed the greatest of— The Secretary shall prescribe regulations setting forth— (Source: (Added Pub. L. 92–178, title V, § 501, Dec. 10, 1971, 85 Stat. 543; amended Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.))