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 https://scholar.law.colorado.edu/faculty-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.
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