23) John Calderwood, Canadian Tax Foundation, supra note 6, expresses agreement (at page 19) with the White Paper's delineation between exact and inexact comparables, and the ambit thereof.
Triplett was quoted as disagreeing with paragraph 45 of the Information Circular in that it does not recognize the impractically of seeking to effectively use inexact comparables for unique high-value intangibles where there are no comparables at all.
The approaches to the selection of comparables outlined in the Report are unremarkable.
The Report emphasizes that application of multiple quantitative screens to select comparables will not, by itself, suffice.
The guidelines do not discuss techniques for narrowing the range of comparables.
482 regulations and the guidelines differ only in their evaluation of the probability that comparable uncontrolled transactions can be identified and that adequate and reliable data about the comparables can reasonably be obtained.
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.
are privately owned) or nonexistent (e.
4824(c)(2)(iii)(A) analyzes comparable
intangible property under comparable