Chapter 3 Section 4: Multi-Jurisdictional Tax Issues in Federal Taxation Flashcards
Define controlled taxpayer
Any of two or more taxpayers owned or controlled directly or indirectly by the same interests
Defined controlled transaction
Any transaction or transfer between two or more members of the same group of controlled taxpayers
Define uncontrolled comparable
Uncontrolled transaction or taxpayer that is compared with a controlled transaction or taxpayer
What is the general idea regarding transfer pricing
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
How is apportionment for state income taxes figured?
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