Northwestern Journal of International Law & Business
Wayne M. Gazur, The Forgotten Link: Control in Section 482, 15 Nw. J. Int'l L. & Bus. 1 (1994), available at http://scholar.law.colorado.edu/articles/768.
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.
Copyright protected. Use of materials from this collection beyond the exceptions provided for in the Fair Use and Educational Use clauses of the U.S. Copyright Law may violate federal law. Permission to publish or reproduce is required.