The U.S. IRS has released two international practice units concerning common ownership and control under IRC Section 482 (transfer pricing), including Common Ownership or Control Under IRC 482 - Inbound, and Common Ownership or Control Under IRC 482 - Outbound. Each practice unit covers the general determination of common ownership and control, with a focus on factors of control, including voting control, management control, acting in concert, and other control considerations.
Internation…