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 …

It is a guide only and not specific to your application. You must be a family member of a primary subclass 482 or 457 visa holder. This temporary visa lets an employer sponsor a suitably skilled …

Aug 25, 2025 · The purpose of IRC 482 is to ensure taxpayers clearly reflect income attributable to controlled transactions and to prevent avoidance of taxes regarding such transactions. IRC 482 …

- The Secretary of the Treasury or his delegate shall conduct a study of the application and administration of section 482 of the Internal Revenue Code of 1986.

Allocation of income and deductions among taxpayers.

Dec 11, 2025 · Review Internal Revenue Code (IRC) Section 482—allocation of income and deductions among taxpayers. Read proposed regulations and the full-text on Tax Notes.

Section 482 places a controlled taxpayer on a tax parity with an uncontrolled taxpayer by determining the true taxable income of the controlled taxpayer. This section sets forth general principles and …

al -- (1) Purpose and scope. The purpose of section 482 is to ensure that taxpayers clearly reflect income attributable to controlled transactions, and t prevent the avoidance of taxes with respect to …

For purposes of section 482 and paragraph (a) of this section, an arm's length rate of interest shall be a rate of interest which was charged, or would have been charged, at the time the indebtedness arose, …

Section 482 of the Code authorizes the IRS to adjust the income, deductions, credits, or allowances of commonly controlled taxpayers to prevent evasion of taxes or to clearly reflect their income.