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Transfer Pricing Crossword

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Across
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Approaches to pricing related party transactions
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Determining the best method may hinge on finding these.
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Key transfer pricing case
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A factor of comparability
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Included in the definition of platform contribution
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Any resource, capability, or right that is reasonably anticipated to contribute to developing cost shared intangibles, 2 words
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Type of basis now required by Sec. 482 post- TCJA
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The L in PLI
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TCJA slashed this tax rate
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Used in estimating RAB shares
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An agreement to use a company's IP to produce and sell products
Down
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Type of intangible now covered by post-TCJA Sec. 482
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Sec. 367(d)(4) now defines it post-TCJA, 2 words
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Appeals makes an assessment of these
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Maintain in court
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Used to convert projected results of transactions to present value, 2 words
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The J in TCJA
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New category of income similar to subpart F, under TCJA
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Low tax country, 2 words
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Type of transaction, two words
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Pre-TCJA certain intangibles were not considered this.
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Type of intangible covered by pre- and post- TCJA Sec. 482
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The F in CFC
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Key transfer pricing case