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TEI believes that the requirements should be limited to what is reasonably necessary to provide examiners with a "road map" or audit trail of a taxpayer's intercompany transactions, including information on the method used and any comparables relied upon.
For example, the regulations could provide that a taxpayer relying on an internal CUP or CUT, or on internal comparables under the resale-price or cost-plus method, will be permitted to make a representation concerning the comparability of the transactions, rather than performing a full-blown functional analysis.
The proposed regulations generally require a comparison of a related party's operating profit ratios with those of comparables for the tax year at issue, as well as the first preceding year and the first succeeding year.
An APA would be especially useful, for example, in making such difficult determinations (required by the proposed regulations) as identifying the tested party, choosing the applicable business classification, determining the relevant comparables and profit-level indicators, making appropriate adjustments, and establishing convergence.
Unless government is prepared to change the nature of the rules and use mechanical (and necessarily arbitrary) apportionment formulae, finding a reasonable arm's-length price in an intercompany transaction (where valid comparables are not available) is not amenable to a comprehensive objective process.
This is not inconsistent with the general notion of an arm's-length standard, or the Canadian rules, (23) and this approach does not detract from the problem discussed earlier that the majority of cases are not in fact governed by comparables nor the problem noted in the U.
The Report emphasizes that application of multiple quantitative screens to select comparables will not, by itself, suffice.
The Report usefully suggests some criteria that are applied in selecting comparables.
With E-COMPS II, a user anywhere in the world can select properties online from any of COMPS' markets nationwide that are most relevant to the subject property and make a credit card transaction to purchase the comparable information.
E-COMPS II, which we consider a revolutionary offering for e-commerce in the commercial real estate information industry, provides the real estate pro a product that has incredible productivity and speed, putting he or she within minutes of getting the sales comparable report they seek," said Wally Papciak, executive vice president of sales, marketing and new product development.
The guidelines do not discuss techniques for narrowing the range of comparables.
The CUT method also applies to related transactions similar but not quite comparable to unrelated transactions.