id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
iiclr-17757	Butlak, Kimberly A.	All's Fair in Love, War, and Taxes: Does the United States Promote Fair Tax Competition in a Global Marketplace Consistent with European Community and Organisation for Economic Co-operation and Development Recommendations Through its Advance Ruling Program?	2002	48	.pdf	application/pdf	25883	1448	56	3 ' B. Consequences of Transfer Pricing Between Foreign and Domestic Related Parties The IRS invokes section 482 most frequently to challenge transfer prices and expense allocations between domestic corporations and foreign affiliates that are not subject to United States tax on foreign income.'39 Within the jurisdiction of the Associate Chief Counsel (International), these topics address: original issue discount, income affected by a treaty, foreign base company income, and dual consolidated losses.75 2. Not ordinarily issued 6 PLRs will not ordinarily be issued when the underlying transaction contemplates whether a business purpose exists or whether a taxpayer uses a correct classification code, contradicts United States tax law designed to effectuate different tax consequences under the tax laws of the United States and of a foreign country, concerns a taxpayer domiciled in a foreign jurisdiction with which the United States does not have an effective mecha- nism for obtaining tax information relevant to the ruling request,77 considers proposed federal, state, local, municipal, or foreign legislation, or interprets foreign law or documents beyond their plain meaning.79 Areas over which rulings are not ordinarily issued that are within the ambit of the remaining, combined Associate Chief Counsel Offices include 71.	cache/iiclr-17757.pdf	txt/iiclr-17757.txt