26 U.S.C. § 482
Allocation of income and deductions among taxpayers
In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses. In the case of any transfer (or license) of intangible property (within the meaning of section 367(d)(4)), the income with respect to such transfer or license shall be commensurate with the income attributable to the intangible. For purposes of this section, the Secretary shall require the valuation of transfers of intangible property (including intangible property transferred with other property or services) on an aggregate basis or the valuation of such a transfer on the basis of the realistic alternatives to such a transfer, if the Secretary determines that such basis is the most reliable means of valuation of such transfers.
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Cited by 91
- 26 CFR § 1.1059A-1 — Limitation on taxpayer's basis or inventory cost in property imported from related persons.
- 26 CFR § 1.1239-1 — Gain from sale or exchange of depreciable property between certain related taxpayers after October 4, 1976.
- 26 CFR § 1.1400Z2(d)-1 — Qualified opportunity funds and qualified opportunity zone businesses.
- 26 CFR § 1.1400Z2(d)-2 — Qualified opportunity zone business property.
- 26 CFR § 1.1441-0 — Outline of regulation provisions for section 1441.
- 26 CFR § 1.1441-2 — Amounts subject to withholding.
- 26 CFR § 1.1471-2 — Requirement to deduct and withhold tax on withholdable payments to certain FFIs.
- 26 CFR § 1.1473-1 — Section 1473 definitions.
- 26 CFR § 1.1502-13 — Intercompany transactions.
- 26 CFR § 1.197-2 — Amortization of goodwill and certain other intangibles.
- 26 CFR § 1.250(b)-4 — Foreign-derived deduction eligible income (FDDEI) sales.
- 26 CFR § 1.263A-1 — Uniform capitalization of costs.
Show 48 more
- 26 CFR § 1.263A-9 — The avoided cost method.
- 26 CFR § 1.267A-2 — Hybrid and branch arrangements.
- 26 CFR § 1.367(a)-1 — Transfers to foreign corporations subject to section 367(a): In general.
- 26 CFR § 1.367(d)-1 — Transfers of intangible property to foreign corporations.
- 26 CFR § 1.367(d)-1T — Transfers of intangible property to foreign corporations (temporary).
- 26 CFR § 1.385-3 — Certain distributions of debt instruments and similar transactions.
- 26 CFR § 1.467-1 — Treatment of lessors and lessees generally.
- 26 CFR § 1.475(a)-4 — Valuation safe harbor.
- 26 CFR § 1.475(c)-1 — Definitions—dealer in securities.
- 26 CFR § 1.482-0 — Outline of regulations under section 482.
- 26 CFR § 1.482-1 — Allocation of income and deductions among taxpayers.
- 26 CFR § 1.482-1A — Allocation of income and deductions among taxpayers.
- 26 CFR § 1.482-1T — Allocation of income and deductions among taxpayers (temporary).
- 26 CFR § 1.482-2 — Determination of taxable income in specific situations.
- 26 CFR § 1.482-4 — Methods to determine taxable income in connection with a transfer of intangible property.
- 26 CFR § 1.482-5 — Comparable profits method.
- 26 CFR § 1.482-7 — Methods to determine taxable income in connection with a cost sharing arrangement.
- 26 CFR § 1.482-9 — Methods to determine taxable income in connection with a controlled services transaction.
- 26 CFR § 1.543-1 — Personal holding company income.
- 26 CFR § 1.56-0 — Table of contents to § 1.56-1, adjustment for book income of corporations.
- 26 CFR § 1.59A-3 — Base erosion payments and base erosion tax benefits.
- 26 CFR § 1.59A-7 — Application of base erosion and anti-abuse tax to partnerships.
- 26 CFR § 1.6038A-1 — General requirements and definitions.
- 26 CFR § 1.6038A-3 — Record maintenance.
- 26 CFR § 1.6038A-4 — Monetary penalty.
- 26 CFR § 1.6038B-2 — Reporting of certain transfers to foreign partnerships.
- 26 CFR § 1.613-4 — Gross income from the property in the case of minerals other than oil and gas.
- 26 CFR § 1.631-3 — Gain or loss upon the disposal of coal or domestic iron ore with a retained economic interest.
- 26 CFR § 1.6662-0 — Table of contents.
- 26 CFR § 1.6662-5 — Substantial and gross valuation misstatements under chapter 1.
- 26 CFR § 1.6662-5T — Substantial and gross valuation misstatements under chapter 1 (temporary).
- 26 CFR § 1.6662-6 — Transactions between persons described in section 482 and net section 482 transfer price adjustments.
- 26 CFR § 1.6664-0 — Table of contents.
- 26 CFR § 1.6664-4T — Reasonable cause and good faith exception to section 6662 penalties.
- 26 CFR § 1.704-1 — Partner's distributive share.
- 26 CFR § 1.7701(l)-4 — Rules regarding inversion transactions.
- 26 CFR § 1.7872-5T — Exempted loans (temporary).
- 26 CFR § 1.7874-12 — Definitions.
- 26 CFR § 1.861-14T — Special rules for allocating and apportioning certain expenses (other than interest expense) of an affiliated group of corporations (temporary).
- 26 CFR § 1.861-17 — Allocation and apportionment of research and experimental expenditures.
- 26 CFR § 1.861-8 — Computation of taxable income from sources within the United States and from other sources and activities.
- 26 CFR § 1.863-1 — Allocation of gross income under section 863(a).
- 26 CFR § 1.865-3 — Source of gross income from sales of personal property (including inventory property) by a nonresident attributable to an office or other fixed place of business in the United States.
- 26 CFR § 1.881-3 — Conduit financing arrangements.
- 26 CFR § 1.901-2 — Income, war profits, or excess profits tax paid or accrued.
- 26 CFR § 1.904-4 — Separate application of section 904 with respect to certain categories of income.
- 26 CFR § 1.907(c)-1 — Definitions relating to FOGEI and FORI (for taxable years beginning after December 31, 1982).
- 26 CFR § 1.907(d)-1 — Disregard of posted prices for purposes of chapter 1 of the Code (for taxable years beginning after December 31, 1982).
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