Contact UsDo you feel the entry into an APA for Section 482 is still meaningful and cost justified?
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Marc Rosen
The answer here is contingent on several variables that have not been enumerated in your question.
For example, the nature of your business, the extent of your foreign affiliates, and the capability of your own tax department to collect and monitor the requisite information, in particular, the availability of comparables for reporting.
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642 weeks ago
For example, the nature of your business, the extent of your foreign affiliates, and the capability of your own tax department to collect and monitor the requisite information, in particular, the availability of comparables for reporting.