| Annual Report |
A report within the meaning of Revenue Procedure 2006-9, section 11.01. |
| APA |
This Advance Pricing Agreement, which is an “advance pricing
agreement” within the meaning of Revenue Procedure 2006-9, section 2.04.
|
| APA Records |
The records specified in Appendix C. |
| APA Request |
Taxpayer’s request for this APA dated , including any amendments
or supplemental or additional information thereto.
|
| Covered Transaction(s) |
This term is defined in Appendix A. |
| Financial Statements |
Financial statements prepared in accordance with U.S. GAAP and stated
in U.S. dollars.
|
| Foreign Group |
Worldwide Group members that are not U.S. persons. |
| Foreign Participants |
[name the foreign entities involved in Covered Transactions]. |
| I.R.C. |
The Internal Revenue Code of 1986, 26 U.S.C., as amended. |
| Pub. L. 106-170 |
The Ticket to Work and Work Incentives Improvement Act of 1999. |
| Revenue Procedure 2006-9 |
Rev. Proc. 2006-9, 2006-2 I.R.B. 278. |
| Transfer Pricing Method (TPM) |
A transfer pricing method within the meaning of Treasury Regulations
section 1.482-1(b) and Revenue Procedure 2006-9, section 2.04.
|
| U.S. GAAP |
U.S. generally-accepted accounting principles. |
| U.S. Group |
Worldwide Group members that are U.S. persons. |
| U.S. Return |
For each taxable year, the “returns with respect to income taxes
under subtitle A” that Taxpayer must “make” in accordance
with I.R.C. section 6012. {Or substitute for partnership: For
each taxable year, the “return” that Taxpayer must “make”
in accordance with I.R.C. section 6031.}
|
| Worldwide Group |
Taxpayer and all organizations, trades, businesses, entities, or branches
(whether or not incorporated, organized in the United States, or affiliated)
owned or controlled directly or indirectly by the same interests.
|
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