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The Forgotten Link: Control In Section 482, Wayne M. Gazur
The Forgotten Link: Control In Section 482, Wayne M. Gazur
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The foundation of international taxable income allocations between related parties is formed by the imposition of an arm's length standard. The presence of "control" over a person invokes this measure. The author examines the implications of control presented by continuing developments in the global business environment, including the rise of cooperative interfirm arrangements.