Then he held her at arm's-length
, and they looked straight into each other's eyes.
What I could not endure without pangs of secret jealousy was that he should like Heine, too, and should read him, though it was but an arm's-length
in an English version.
Conscious of having honestly presented himself at the inn in Anne's interests, as well as in the interests of the ladies at Windygates, it appealed to his sense of humor to find himself kept at arm's-length
by the very woman whom he had come to benefit.
These documentation requirements are intended to facilitate the tax authority's understanding of the tax-payer's intercompany transactions and assessment of whether and the extent to which income has been calculated in accordance with the arm's-length
The PATA documentation guide notes that "each PATA member has different legal systems, statutes, regulations and administrative approaches with respect to transfer pricing." Thus, the documentation package acknowledges, but does not address, the root cause of compliance burdens encountered by multinational national enterprises: inconsistency among various jurisdictions either in the substantive transfer-pricing rules or in their administration, especially in respect of how the taxpayer's compliance with the arm's-length
standard is to be evaluated.
In comments on regulations proposed by the Internal Revenue Service under tax code section 482-- concerning intercompany transfer pricing--the American Institute of CPAs emphasized regulations should be fully consistent with the arm's-length
follows the internationally accepted arm's-length
principle, which aims to treat all transactions as if they were between unrelated parties, for economic and tax purposes.
The section 482 approach to services, however, has focused more on the reallocation of income under an arm's-length
standard, which injects an additional consideration of valuing the services as if provided by an unrelated party.
It also is argued valuation of internally generated goodwill is based on "softer" numbers--there is no bargained arm's-length
exchange--and is dependent on an ever moving target, the company's current share price.
Because a large intercompany receivable between two entities lacked either economic substance or arm's-length
terms, the DOT ruled (96) that a taxpayer had to file a consolidated state corporate income tax return with its wholly owned mail-order supply company.
Preliminary preparatory work, however, was to be performed in Canada by an independent agent (an arm's-length
company) resident in Canada.
In a scathing opinion for both sides, Judge Hamblen held SunPac was not a subcontractor and the IRS's adjustment was unreasonable, even though the royalty and transfer price were not "arm's length." He determined a proper royalty was 10% and the arm's-length
transfer price should be the catalog price less a 20% discount.