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Competent authority under the simultaneous appeals

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Reference no: EM131055429

USAco is the wholly-owned United States subsidiary of ASIAco, a foreign corporation. USAcopurchases automobiles from ASIAco for $20,000, and resells the automobiles for $21,000. The IRSconducts a transfer pricing examination of USAco and proposes an adjustment based on what it believes to be the arm's length transfer price of $15,000. USAco decides to pursue the issue at bothAppeals and Competent Authority under the Simultaneous Appeals Procedure ("SAP").Describe the SAP procedures.

Reference no: EM131055429

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