Open Access. Powered by Scholars. Published by Universities.®

Law Commons

Open Access. Powered by Scholars. Published by Universities.®

Series

International taxation

Articles

Comparative and Foreign Law

Articles 1 - 1 of 1

Full-Text Articles in Law

The Forgotten Link: Control In Section 482, Wayne M. Gazur Jan 1994

The Forgotten Link: Control In Section 482, Wayne M. Gazur

Articles

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.