The Implications in and for Canada of the Irs's Final Section 482 Services Regulations

Overview In principle, there ought to have been no need to write this article. The reasons are threefold. First, the principle underlying the tax rule governing cross-border intercompany transactions in Canada and the United States is the same: namely, intercompany prices are to be governed by the arm's-length standard. In the United States, this is expressed in the regulations pursuant to section 482 of the Internal Revenue Code. (1) In particular, Treas. Reg. [section] 1.482-1(b)(1) states, in part: