Paragraph 1. The authority citation for part 1 is amended by adding
an entry in numerical order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 1.482-9 also issued under 26 U.S.C. 482. * * *
Par. 2. Section 1.482-0 is amended as follows:
1. The section heading is revised.
2. The entries for §1.482-2(b) are revised.
3. The entries for §1.482-4(f)(3), (f)(4) and (f)(5) are revised
and new entries for §1.482-4(f)(6) are added.
4. New entries for §§1.482-6T(c)(3)(i)(B)(1) and (2) and 1.482-9T
are added.
The revisions and additions read as follows:
§1.482-0 Outline of regulations under section 482.
* * * * *
[The text of the proposed amendment to §1.482-0 is the same as
the text of §1.482-0T published elsewhere in this issue of the Bulletin].
Par. 3. Section 1.482-1 is amended as follows:
1. Paragraphs (a)(1), (b)(2)(i), (d)(3)(ii)(C) Example 3, (d)(3)(v),
(f)(2)(ii)(A), (f)(2)(iii)(B), (g)(4)(i), (g)(4)(iii) and paragraph (i) are
revised.
2. Paragraphs (d)(3)(ii)(C), Example 4, Example 5, and Example 6, and
(j)(6) are added.
The additions and revisions read as follows:
§1.482-1 Allocation of income and deductions among taxpayers.
(a)(1) [The text of the proposed amendment to §1.482-1(a)(1) is
the same as the text of §1.482-1T(a)(1) published elsewhere in this issue
of the Bulletin].
* * * * *
(b) * * * (1) * * *
(b)(2)(i) [The text of the proposed amendment to §1.482-1(b)(2)(i)
is the same as the text of §1.482-1T(b)(2)(i) published elsewhere in
this issue of the Bulletin].
* * * * *
(d) * * *
(3) * * *
(ii) * * *
(C) * * *
Example 3. [The text of the proposed amendment
to §1.482-1(d)(3)(ii)(C), Example 3 is the same
as the text of §1.482-1T(d)(3)(ii)(C) Example 3 published
elsewhere in this issue of the Bulletin].
Example 4. [The text of the proposed amendment
to §1.482-1(d)(3)(ii)(C) Example 4 is the same as
the text of §1.482-1T(d)(3)(ii)(C) Example 4 published
elsewhere in this issue of the Bulletin].
Example 5. [The text of the proposed amendment
to §1.482-1(d)(3)(ii)(C) Example 5 is the same as
the text of §1.482-1T(d)(3)(ii)(C) Example 5 published
elsewhere in this issue of the Bulletin].
Example 6. [The text of the proposed amendment
to §1.482-1(d)(3)(ii)(C) Example 6 is the same as
the text of §1.482-1T(d)(3)(ii)(C) Example 6 published
elsewhere in this issue of the Bulletin].
(v) Property or services. [The text of the proposed
amendment to §1.482-1(d)(3)(v) is the same as the text of §1.482-1T(d)(3)(v)
published elsewhere in this issue of the Bulletin].
* * * * *
(f) * * *
(2) * * *
(ii)(A) [The text of the proposed amendment to §1.482-1(f)(2)(ii)(A)
is the same as the text of §1.482-1T(f)(2)(ii)(A) published elsewhere
in this issue of the Bulletin].
(iii) * * *
(B) [The text of the proposed amendment to §1.482-1(f)(3)(iii)(B)
is the same as the text of §1.482-1T(f)(3)(iii)(B) published elsewhere
in this issue of the Bulletin].
* * * * *
(g) * * *
(4) * * * (i) * * * [The text of the proposed amendment to §1.482-1(g)(4)(i)
is the same as the text of §1.482-1T(g)(4)(i) published elsewhere in
this issue of the Bulletin].
(iii) * * *
Example 1. [The text of the proposed amendment
to §1.482-1(g)(4)(iii) Example 1 is the same as
the text of §1.482-1T(g)(4)(iii) Example 1 published
elsewhere in this issue of the Bulletin].
* * * * *
(i) [The text of the proposed amendment to §1.482-1(i) is the same
as the text of §1.482-1T(i) published elsewhere in this issue of the
Bulletin].
* * * * *
(j) [The text of the proposed amendment to §1.482-1(j)(6) is the
same as the text of §1.482-1T(j)(6) published elsewhere in this issue
of the Bulletin].
Par. 4. Section 1.482-2 is amended as follows:
1. Paragraph (b) is revised.
2. Paragraph (e) is added.
The revision and addition reads as follows:
§1.482-2 Determination of taxable income in specific
situations.
* * * * *
(b) [The text of the proposed amendment to §1.482-2(b) is the
same as the text of §1.482-2T(b) published elsewhere in this issue of
the Bulletin].
* * * * *
(e) [The text of the proposed amendment to §1.482-2(e) is the
same as the text of §1.482-2T(e)(1) and (2) published elsewhere in this
issue of the Bulletin].
Par. 5. Section 1.482-4 is amended as follows:
1. Paragraph (f)(3) is revised.
2. Paragraphs (f)(4) and (f)(5) are redesignated as paragraphs (f)(5)
and (f)(6), respectively.
3. New paragraphs (f)(4) and (f)(7) are added.
The revision and addition read as follows:
§1.482-4 Methods to determine taxable income in connection
with a transfer of intangible property.
* * * * *
(f) * * *
(3) [The text of the proposed amendment to §1.482-4(f)(3) is the
same as the text of §1.482-4T(f)(3) published elsewhere in this issue
of the Bulletin].
* * * * *
(4) [The text of the proposed amendment to §1.482-4(f)(4) is the
same as the text of §1.482-4T(f)(4) published elsewhere in this issue
of the Bulletin].
* * * * *
(7) [The text of the proposed amendment to §1.482-4(f)(7) is the
same as the text of §1.482-4T(f)(7)(i) and (ii) published elsewhere in
this issue of the Bulletin].
* * * * *
Par. 6. Section 1.482-6 is amended by revising paragraphs (c)(2)(ii)(B)(1),
(c)(2)(ii)(D), (c)(3)(i)(A), (c)(3)(i)(B), and (c)(3)(ii)(D), and adding paragraph
(d) to read as follows:
§1.482-6 Profit split method.
* * * * *
(c) * * *
(2) * * *
(ii) * * *
(B) * * * (1) * * * [The text of the proposed amendment to §1.482-6(c)(2)(ii)(B)(1)
is the same as the text of §1.482-6T(c)(2)(ii)(B)(1) published elsewhere
in this issue of the Bulletin].
* * * * *
(D) [The text of the proposed amendment to §1.482-6(c)(2)(ii)(D)
is the same as the text of §1.482-6T(c)(2)(ii)(D) published elsewhere
in this issue of the Bulletin].
* * * * *
(3) * * *
(i) * * * (A) [The text of the proposed amendment to §1.482-6(c)(3)(i)(A)
is the same as the text of §1.482-6T(c)(3)(i)(A) published elsewhere
in this issue of the Bulletin].
(B) [The text of the proposed amendment to §1.482-6(c)(3)(i)(B)
is the same as the text of §1.482-6T(c)(3)(i)(B) published elsewhere
in this issue of the Bulletin].
* * * * *
(ii) * * *
(D) [The text of the proposed amendment to §1.482-6(c)(3)(ii)(D)
is the same as the text of §1.482-6T(c)(3)(ii)(D) published elsewhere
in this issue of the Bulletin].
* * * * *
(d) [The text of the proposed amendment to §1.482-6(d) is the same
as the text of §1.482-6T(d)(1) and (2) published elsewhere in this issue
of the Bulletin].
Par. 7. Section 1.482-8 is amended by adding Examples 10 through 12
to read as follows:
§1.482-8 Examples of the best method rule.
* * * * *
(b) * * * Example 10. Cost of services
plus method preferred to other methods.[The text of the proposed
amendment to §1.482-8(a) Example 10 is the same
as the text of §1.482-8T(a) Example 10 published
elsewhere in this issue of the Bulletin].
Example 11. CPM for services preferred
to other methods. [The text of the proposed amendment to §1.482-8(a) Example
11 is the same as the text of §1.482-8T(a) Example
11 published elsewhere in this issue of the Bulletin].
Example 12. Residual profit split preferred
to other methods. [The text of the proposed amendment to §1.482-8(a) Example
12 is the same as the text of §1.482-8T(a) Example
12 published elsewhere in this issue of the Bulletin].
Par. 8. A new §1.482-9 is added to read as follows:
§1.482-9 Methods to determine taxable income in connection
with a controlled services transaction.
(a) through (m)(5) [The text of the proposed §1.482-9(a) through
(m)(5) is the same as the text of §1.482-9T(a) through (m)(5) published
elsewhere in this issue of the Bulletin].
(m)(6) Global dealing operations. A controlled
services transaction does not include a financial transaction entered into
in connection with a global dealing operation as defined in the current proposed
§1.482-8.
(n) [The text of the proposed §1.482-9(n) is the same as the text
of §1.482-9T(n)(1) and (n)(2) published elsewhere in this issue of the
Bulletin].
Par. 9. Section 1.861-8 is amended by revising paragraphs (a)(5), the
fifth and sixth sentences in paragraph (b)(3), (e)(4), (f)(4)(i), (g) Examples
17, 18, and 30, and the
first sentence in paragraph (h) introductory text to read as follows:
§1.861-8 Computation of taxable income from sources
within the United States and from other sources and activities.
(a) * * *
(5) [The text of the proposed amendment to §1.861-8(a)(5) is the
same as the text of §1.861-8T(a)(5) published elsewhere in this issue
of the Bulletin].
(b) * * *
(3) * * * [The text of the proposed amendment to §1.861-8(b)(3)
is the same as the text in §1.861-8T(b)(3) published elsewhere in this
issue of the Bulletin]. * * *
* * * * *
(e) * * *
(4) [The text of the proposed amendment to §1.861-8(e)(4) is the
same as the text of §1.861-8T(e)(4) published elsewhere in this issue
of the Bulletin].
(f) * * *
(4)* * * (i) [The text of the proposed amendment to §1.861-8(f)(4)(i)
is the same as the text of §1.861-8T(f)(4)(i) published elsewhere in
this issue of the Bulletin].
(g) * * *
Example 17. [The text of the proposed amendment
to §1.861-8(g) Example 17 is the same as the text
of §1.861-8T(g) Example 17, published elsewhere
in this issue of the Bulletin].
Example 18. [The text of the proposed amendment
to §1.861-8(g) Example 18 is the same as the text
of §1.861-8T(g) Example 18, published elsewhere
in this issue of the Bulletin].
* * * * *
Example 30. [The text of the proposed amendment
to §1.861-8(g) Example 30 is the same as the text
of §1.861-8T(g) Example 30, published elsewhere
in this issue of the Bulletin].
(h) [The text of the proposed amendment to §1.861-8(h) is the same
as the text of §1.861-8T(h) published elsewhere in this issue of the
Bulletin]. * * *
* * * * *
Par. 10. Section 1.6038A-3(a)(3) is amended by revising paragraph (a)(3) Example
4 and (i) to read:
§1.6038A-3 Record maintenance.
(a) * * *
(3) * * *
Example 4. [The text of the proposed amendment
to §1.6038A-3, Example 4 is the same as the text
of §1.6038A-3T, Example 4 published elsewhere in
this issue of the Bulletin].
* * * * *
(i) [The text of the proposed amendment to §1.6038A-3(i) is the
same as the text of §1.6038A-3T(i)(1) and (2) published elsewhere in
this issue of the Bulletin].
Par. 11. Section 1.6662-6 is amended by revising paragraphs (d)(2)(ii)(B),
(d)(2)(iii)(B)(4), (d)(2)(iii)(B)(6) and (g) to read as follows:
§1.6662-6 Transactions between persons described in
section 482 and net section 482 transfer price adjustments.
* * * * *
(d) * * *
(2) * * *
(ii) * * *
(B) [The text of the proposed amendment to §1.6662-6(d)(2)(ii)(B)
is the same as the text of §1.6662-6T(d)(2)(ii)(B) published elsewhere
in this issue of the Bulletin].
* * * * *
(iii) * * *
(B) * * * (4) [The text of the proposed amendment to §1.6662-6(d)(2)(iii)(B)(4)
is the same as the text of §1.6662-6T(d)(2)(iii)(B)(4) published elsewhere
in this issue of the Bulletin].
* * * * *
(6) [The text of the proposed amendment to §1.6662-6(d)(2)(iii)(B)(6)
is the same as the text of §1.6662-6T(d)(2)(iii)(B)(6) published elsewhere
in this issue of the Bulletin].
* * * * *
(g) [The text of the proposed amendment to §1.6662-6(g) is the
same as the text of §1.6662-6T(g)(1) and (2) published elsewhere in this
issue of the Bulletin].
