In the case of any transfer (or license) of intangible property (within the meaning of section 367 (d) (4)), the income with respect to such transfer or license shall be commensurate with the …

This temporary visa lets an employer sponsor a suitably skilled worker to fill a position they can’t find a suitably skilled Australian to fill. Skilled visa income thresholds are increasing in line with …

al -- (1) Purpose and scope. The purpose of section 482 is to ensure that taxpayers clearly reflect income attributable to controlled transactions, and t prevent the avoidance of taxes with …

- The Secretary of the Treasury or his delegate shall conduct a study of the application and administration of section 482 of the Internal Revenue Code of 1986.

Find out who that 482 phone number is registered to. Our free reverse phone lookup allows you to search records associated with a landline or cell phone number to help quickly identify who’s …

Allocation of income and deductions among taxpayers.

In the case of any transfer (or license) of intangible property (within the meaning of section 367 (d) (4)), the income with respect to such transfer or license shall be commensurate with the …

Dec 11, 2025 · Review Internal Revenue Code (IRC) Section 482—allocation of income and deductions among taxpayers. Read proposed regulations and the full-text on Tax Notes.

Jan 1, 2024 · In the case of any transfer (or license) of intangible property (within the meaning of section 367 (d) (4)), the income with respect to such transfer or license shall be commensurate …

Section 482 places a controlled taxpayer on a tax parity with an uncontrolled taxpayer by determining the true taxable income of the controlled taxpayer. This section sets forth general …