Tag: Intent to avoid taxes not prerequisite

§ 1.482-1(f)(1)(i) Intent to evade or avoid tax not a prerequisite.

/ Intent to avoid taxes not prerequisite, Tax avoidance, Transfer Pricing Adjustment  , Transfer pricing audit, US IRC Section 482 on Transfer Pricing, § 1.482-1 Allocation of income and deductions among taxpayers
In making allocations under section 482, the district director is not restricted to the case of improper accounting, to the case of a fraudulent, colorable, or sham transaction, or to the case of a device designed to reduce or avoid tax by shifting or distorting income, deductions, credits, or allowances ... Read more