2014-02-22
Below is a chart of Central de Gas de Chihuahua v. Commissioner, 102 T.C. 515 (1994). The Tax Court held that the Code §482 adjustment made by the IRS was appropriate where one Mexican corporation, Central Gas, allowed a related Mexican corporation the rent-free use of tractors which were used in the U.S. The Code §482 adjustment created deemed rental payments to Central Gas which were U.S. source income.
The chart can be viewed as a PDF file here: Central de Gas de Chihuahua.
We will shortly add this chart to andrewmitchel.com, where you can find hundreds of similar situational charts.
For some recent commentary on transfer pricing, visit Paul Caron's TaxProf Blog.
