§ 1.482-2(a)(1)(iii)(C) Exception for trade or business of debtor member located outside the United States.

Posted on | By Internal Revenue Service
Category: US IRC Section 482 on Transfer Pricing, § 1.482-2 Determination of taxable income in specific situations. | Tag: , , , ,
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In the case of an intercompany trade receivable arising from a transaction in the ordinary course of a trade or business which is actively conducted outside the United States by the debtor member, interest is not required to be charged until the first day of the fourth calendar month following the month in which such intercompany trade receivable arises.

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