Controlled directly or indirectly by the same interests

Assignment Help Other Subject

Reference no: EM133812817

Question

In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses. 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 income attributable to the intangible. For purposes of this section, the Secretary shall require the valuation of transfers of intangible property (including intangible property transferred with other property or services) on an aggregate basis or the valuation of such a transfer on the basis of the realistic alternatives to such a transfer, if the Secretary determines that such basis is the most reliable means of valuation of such transfers.

Summarize the purpose of the code section in your own words

Reference no: EM133812817

Questions Cloud

Covenants are entered into by two parties as contract : Covenants are entered into by two parties as a contract and therefore should not bind any other party who owns the land" Critically evaluate this statement

Front door carrying some garbage bags : After some time, they noticed a man that they recognize as an AHS employee come out the front door carrying some garbage bags.

Provides systems engineering and technical direction : According to FAR Subpart 9.5, Organizational and Consultant Conflicts of Interest, a contractor that provides systems engineering and technical direction

Controlled directly or indirectly by the same interests : Controlled directly or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits,

Warm spring day and the windows were open : Ruby and Bubba got into a shouting match in their living room. It was a warm spring day and the windows were open.

Defendant agree on consent to proceed : The defendant agree on a Consent to Proceed Before a United States Magistrate Judge before it is granted or can just either party request it to be granted?

What are the effects of insanity plea : What are the effects of an insanity plea according to the video and your independent research via the internet?

Klaus of the silos stability during contract negotiations : The parol evidence rule will preclude evidence that Font, aware of the problem, assured Klaus of the silo's stability during contract negotiations.

User Account

All Pages