Chapter 3 Section 4: Multi-Jurisdictional Tax Issues in Federal Taxation Flashcards

1
Q

Define controlled taxpayer

A

Any of two or more taxpayers owned or controlled directly or indirectly by the same interests

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2
Q

Defined controlled transaction

A

Any transaction or transfer between two or more members of the same group of controlled taxpayers

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3
Q

Define uncontrolled comparable

A

Uncontrolled transaction or taxpayer that is compared with a controlled transaction or taxpayer

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4
Q

What is the general idea regarding transfer pricing

A

If the product is made in the US, then sold to an affiliate i a country with lower taxes to be sold, you need to sell it to the affiliate at a price that is comparable to what you would sell it at in an arms-length transaction

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5
Q

How is apportionment for state income taxes figured?

A

Product of the apportionment factor based on property, payroll, and sales in the state times the portion of line 28 income which is apportionable, business income

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