A binding contract between the IRS and the taxpayer with which the IRS agrees not to seek

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A binding contract between the IRS and the taxpayer with which the IRS agrees not to seek a transfer pricing adjustment for a covered transaction if the taxpayer files its return consistent with the agreed transfer pricing method is called a(n):

a. Section 482 study.
b. Advance Pricing Agreement Program.
c. Request for competent authority.
d. Controlled transaction analysis agreement.

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South-Western Federal Taxation 2022 Corporations, Partnerships, Estates And Trusts

ISBN: 9780357519240

45th Edition

Authors: William A. Raabe, James C. Young, Annette Nellen, William H. Hoffman

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