Question

Kantor Inc. owns 100 percent of Sub 1 (a CFC in a country with a 50 percent corporate tax) and 90 percent of Sub 2 (a CFC in a country with a 10 percent corporate tax). Kantor sells goods and services to both CFCs. Is the IRS more interested in Kantor’s transfer pricing for sales to Sub 1 or sales to Sub 2?


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  • CreatedNovember 03, 2015
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