Section 482: Transfer Pricing Problems and International Tax Planning Opportunities

Bruce Givner, Esq.August 21 - Section 482: Transfer Pricing Problems and International Tax Planning Opportunities

Bruce Givner, Esq.
Givner & Kaye, A Professional Corporation







Bruce Givner:

Section 482 dates back to 1921
. Perhaps the most powerful
weapon of the IRS, it consists of two sentences. Congress’s
intent was (1) to prevent tax evasion by the manipulation of
transactions between business entities controlled by the
same person(s), and (2) even where no tax evasion motive is
present, to ensure that the
tax liability of the controlled
business entities is based on their “true” income. Most
people think of this in the context of a U.S. parent
overpaying a foreign subsidiary located in a low-tax
jurisdiction so as to “bury” profits abroad. However, the IRS
applies Section 482 with equal vigor domestically, e.g., when
an operating business overpays for insurance offered by its
captive insurance company. We will discuss some problems
of interpretation under the statute; interpreting the arm’s
length standard in the regulations; the best method rule;
and some examples.

Bring your questions and concerns.

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Enter your contact info to RSVP for this seminar.
Date: Thursday August 21, 2014
Time:
2:30pm - 4:00pm
Location:
The Law Offices of Givner & Kaye, APC.
12100 Wilshire Blvd., Suite 445
Los Angeles, CA 90025

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