Low margin covered services are controlled services transactions for which the median comparable markup on total services costs is less than or equal to seven ...

Section 1.482-9 - Methods to determine taxable income in connection with a controlled services transaction. Date.

(b) Rendering of services. * * * **. §1.482-4 Methods to determine taxable income in connection with a transfer of intangible property.

(a) In general -- (1) Purpose and scope. The purpose of section 482 is to ensure that taxpayers clearly reflect income.

Aug 4, 2009 · This document contains final regulations that provide guidance regarding the treatment of controlled services transactions under section 482 ...

Section § 1.482-9 - Methods to determine taxable income in connection with a controlled services transaction. Date.

FORM FDA 482 (9/11). Sec. 704. (d) Whenever in the course of any such inspection of a factory or other establishment where food is manufactured, processed, ...

Aug 31, 2010 · Sec. 482 places a controlled taxpayer on tax parity with an uncontrolled taxpayer by determining the “true” taxable income of the controlled ...

This section contains major captions for §§ 1.482-1 through 1.482-9. § 1.482-1 Allocation of income and deductions among taxpayers. (a) In general.

The following types of activities are excluded activities: (i) Manufacturing. (ii) Production. (iii) Extraction, exploration, or processing of natural.