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Taxpayers would be well served to review their proposed comparables (whether in pricing studies or proposed APAs) for these factors before the IRS does.
The Report provides useful examples of how to screen comparables for the presence or absence of intangibles.
These methods include the comparable uncontrolled price method, the resale method and the cost plus method.
482 regulations, a taxpayer may use the comparable profits method (CPM) or the profit split method; under the guidelines, a taxpayer may use the profit split method or the transactional net margin method (TNMM).
9) More important, the "make-orbuy" analysis--which could eliminate the use of potential comparables by hypothesizing what a taxpayer could have done--is contrary to the principle that a taxpayer may structure its tax affairs in any reasonable manner.
The limitation on the use of the profit-split method under the regulations will effectively force taxpayers to use the comparable profits or an "other" method when comparables are unavailable.
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.
I had tears in my eyes remembering the hoops that I had to jump through to get comparable (information) out of our (San Francisco) market area when I was a broker," Pike said, referring to how much slower the overall process was in past years.
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.
15 In applying these methods, the realm of comparables has been expanded by eliminating the rigid geographical and temporal restrictions of prior law.
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.
Comparable intangibles: While identical intangibles are rare, comparable intangibles are relatively more common.