Internal Revenue Code Section 482: Primary U.S. tax regulation governing transfer pricing between related entities, ensuring transactions are conducted at arm's length
Treasury Regulations ��1.482: Detailed implementation guidelines for transfer pricing rules, including methods for determining appropriate pricing and cost allocation
State Corporate Laws: Legal framework governing corporate entities' operations and transactions within specific states where entities are incorporated
Securities Exchange Act: Federal regulations applicable when any party to the agreement is publicly traded, including disclosure requirements
GAAP Compliance: Generally Accepted Accounting Principles that must be followed for financial reporting and cost allocation methods
FASB Guidelines: Financial Accounting Standards Board directives for accounting treatment of intercompany transactions and cost allocations
Cost Accounting Standards: Specialized accounting standards particularly relevant if government contracts are involved in the business relationship
OECD Transfer Pricing Guidelines: International standards for transfer pricing that may affect U.S. intercompany agreements with international implications
BEPS Rules: Base Erosion and Profit Shifting regulations designed to prevent tax avoidance through international transfer pricing manipulation
Foreign Tax Treaties: Bilateral agreements between the U.S. and other countries affecting taxation of intercompany transactions across borders
FCPA: Foreign Corrupt Practices Act requirements for maintaining accurate books and records in international business transactions
Uniform Commercial Code: Standardized state laws governing commercial transactions, including contract formation and enforcement
Statute of Frauds: Legal requirement that certain contracts must be in writing to be enforceable
Transfer Pricing Documentation: Required documentation to support the pricing methodology and demonstrate compliance with transfer pricing regulations
IRS Form 5471: Information return required for U.S. persons with respect to certain foreign corporations involved in intercompany transactions
