IRC Section 482: Primary Internal Revenue Code section governing transfer pricing regulations and adjustments between related entities
IRC Section 7121: Internal Revenue Code section providing authority for the IRS to enter into binding closing agreements with taxpayers, which forms the legal basis for APAs
Revenue Procedure 2015-41: IRS guidance document outlining detailed procedures for requesting, negotiating, and executing Advance Pricing Agreements
Treasury Regulations �� 1.482-1 through 1.482-9: Detailed regulations implementing IRC 482, providing specific guidance on transfer pricing methods and requirements
OECD Transfer Pricing Guidelines: International guidelines that, while not legally binding in the US, provide influential guidance on transfer pricing principles and methodologies
U.S. Tax Treaties: Bilateral agreements between the US and other countries that may affect transfer pricing arrangements and need to be considered in APAs
IRS Practice Unit on APAs: Internal IRS guidance document providing detailed information on APA procedures and requirements
IRC Sections 6662(e) and (h): Provisions regarding transfer pricing penalties and documentation requirements to avoid such penalties
Revenue Procedure 99-32: Guidance on the treatment of transfer pricing adjustments and conforming adjustments
IRS Form 14470: Official form required for submitting an Advance Pricing Agreement request to the IRS
State Tax Implications: Consideration of state-specific tax laws and regulations that may impact the APA
Industry-Specific Regulations: Relevant industry-specific rules and regulations that may affect transfer pricing arrangements
