§482. Allocation of income and deductions among taxpayers — Inbound Citations

Citations to 26 U.S.C. § 482 as a whole

• 6 U.S.C. § 395(c)(1)(D)

  Go to provision →
  (D) For purposes of applying subsection (b) to the acquisition of a domestic partnership, except as provided in regulations, all domestic partnerships which are under common control (within the meaning of section 482 of title 26) shall be treated as I¹ partnership.
• 26 U.S.C. § 51(c)(2)(B)

  Go to provision →
  (B) The amount of wages which would (but for this subparagraph) be qualified wages under this section for an employer with respect to an individual for a taxable year shall be reduced by an amount equal to the amount of the payments made to such employer (however utilized by such employer) with respect to such individual for such taxable year under a program established under section 482(e)¹ of the Social Security Act.
• 26 U.S.C. § 59A(d)(5)(A)

  Go to provision →
  (A) such services are services which meet the requirements for eligibility for use of the services cost method under section 482 (determined without regard to the requirement that the services not contribute significantly to fundamental risks of business success or failure), and
• 26 U.S.C. § 59A(g)(1)(C)

  Go to provision →
  (C) any other person who is related (within the meaning of section 482) to the taxpayer.
• 26 U.S.C. § 845(a)

  Go to provision →
  (a) In the case of 2 or more related persons (within the meaning of section 482) who are parties to a reinsurance agreement (or where one of the parties to a reinsurance agreement is, with respect to any contract covered by the agreement, in effect an agent of another party to such agreement or a conduit between related persons), the Secretary may—

  (1) allocate between or among such persons income (whether investment income, premium, or otherwise), deductions, assets, reserves, credits, and other items related to such agreement,

  (2) recharacterize any such items, or

  (3) make any other adjustment,

  if he determines that such allocation, recharacterization, or adjustment is necessary to reflect the proper amount, source, or character of the taxable income (or any item described in paragraph (1) relating to such taxable income) of each such person.
• 26 U.S.C. § 857(b)(7)(B)(i)

  Go to provision →
  (i) The term “redetermined rents” means rents from real property (as defined in section 856(d)) to the extent the amount of the rents would (but for subparagraph (F)) be reduced on distribution, apportionment, or allocation under section 482 to clearly reflect income as a result of services furnished or rendered by a taxable REIT subsidiary of the real estate investment trust to a tenant of such trust.
• 26 U.S.C. § 857(b)(7)(C)

  Go to provision →
  (C) The term “redetermined deductions” means deductions (other than redetermined rents) of a taxable REIT subsidiary of a real estate investment trust to the extent the amount of such deductions would (but for subparagraph (F)) be decreased on distribution, apportionment, or allocation under section 482 to clearly reflect income as between such subsidiary and such trust.
• 26 U.S.C. § 901(i)(1)

  Go to provision →
  (1) the amount of such tax is used (directly or indirectly) by the country imposing such tax to provide a subsidy by any means to the taxpayer, a related person (within the meaning of section 482), or any party to the transaction or to a related transaction, and
• 26 U.S.C. § 994(a)

  Go to provision →
  (a) In the case of a sale of export property to a DISC by a person described in section 482, the taxable income of such DISC and such person shall be based upon a transfer price which would allow such DISC to derive taxable income attributable to such sale (regardless of the sales price actually charged) in an amount which does not exceed the greatest of—

  (1) 4 percent of the qualified export receipts on the sale of such property by the DISC plus 10 percent of the export promotion expenses of such DISC attributable to such receipts,

  (2) 50 percent of the combined taxable income of such DISC and such person which is attributable to the qualified export receipts on such property derived as the result of a sale by the DISC plus 10 percent of the export promotion expenses of such DISC attributable to such receipts, or

  (3) taxable income based upon the sale price actually charged (but subject to the rules provided in section 482).
• 26 U.S.C. § 994(a)(3)

  Go to provision →
  (3) taxable income based upon the sale price actually charged (but subject to the rules provided in section 482).
• 26 U.S.C. § 1059A(a)

  Go to provision →
  (a) If any property is imported into the United States in a transaction (directly or indirectly) between related persons (within the meaning of section 482), the amount of any costs—

  (1) which are taken into account in computing the basis or inventory cost of such property by the purchaser, and

  (2) which are also taken into account in computing the customs value of such property,

  shall not, for purposes of computing such basis or inventory cost for purposes of this chapter, be greater than the amount of such costs taken into account in computing such customs value.
• 26 U.S.C. § 1358(c)

  Go to provision →
  (c) Section 482 applies in accordance with this subsection to a transaction or series of transactions—

  (1) as between an electing corporation and another person, or

  (2) as between a person’s qualifying shipping activities and other activities carried on by it.
• 26 U.S.C. § 6038A(c)(2)(C)

  Go to provision →
  (C) any other person who is related (within the meaning of section 482) to the reporting corporation.
• 26 U.S.C. § 6038B(b)(2)

  Go to provision →
  (2) If by reason of an adjustment under section 482 or otherwise, a contribution described in subsection (a)(1) is deemed to have been made, such contribution shall be treated for purposes of this section as having been made not earlier than the date specified by the Secretary.
• 26 U.S.C. § 6662(e)(1)(B)(i)

  Go to provision →
  (i) the price for any property or services (or for the use of property) claimed on any such return in connection with any transaction between persons described in section 482 is 200 percent or more (or 50 percent or less) of the amount determined under section 482 to be the correct amount of such price, or
• 26 U.S.C. § 6662(e)(1)(B)(ii)

  Go to provision →
  (ii) the net section 482 transfer price adjustment for the taxable year exceeds the lesser of $5,000,000 or 10 percent of the taxpayer’s gross receipts.
• 26 U.S.C. § 6662(e)(3)(A)

  Go to provision →
  (A) The term “net section 482 transfer price adjustment” means, with respect to any taxable year, the net increase in taxable income for the taxable year (determined without regard to any amount carried to such taxable year from another taxable year) resulting from adjustments under section 482 in the price for any property or services (or for the use of property).
• 26 U.S.C. § 6662(e)(3)(B)(i)(I)

  Go to provision →
  (I) it is established that the taxpayer determined such price in accordance with a specific pricing method set forth in the regulations prescribed under section 482 and that the taxpayer’s use of such method was reasonable,
• 26 U.S.C. § 6662(e)(3)(D)

  Go to provision →
  (D) For purposes of section 6664(c) the taxpayer shall not be treated as having reasonable cause for any portion of an underpayment attributable to a net section 482 transfer price adjustment unless such taxpayer meets the requirements of clause (i), (ii), or (iii) of subparagraph (B) with respect to such portion.
• 26 U.S.C. § 7874(c)(5)

  Go to provision →
  (5) For purposes of applying subsection (a)(2)(B)(ii) to the acquisition of a trade or business of a domestic partnership, except as provided in regulations, all partnerships which are under common control (within the meaning of section 482) shall be treated as 1 partnership.
• 26 U.S.C. § 7874(d)(3)(B)

  Go to provision →
  (B) is under the same common control (within the meaning of section 482) as such entity.