Tag: Trade Or Business  

A regular and continuous activity undertaken for a profit, other than that of an investor trading in securities.

§ 1.482-7(j)(2)(ii) Trade or business.

/ CCA/CSA, CCA/CSA - methods for pricing, Cost Contribution Arrangement (CCA), Cost Sharing Arrangement (CSA), Special Rules, Trade Or Business  , US IRC Section 482 on Transfer Pricing, § 1.482-7 Methods to determine taxable income in connection with a cost sharing arrangement
A participant that is a foreign corporation or nonresident alien individual will not be treated as engaged in a trade or business within the United States solely by reason of its participation in a CSA. See generally § 1.864-2(a) ... Read more