Section 482 Allocations: General Principles in the Code and Regulations (Portfolio 551)

Description

Bloomberg Tax Portfolio, Section 482 Allocations: General Principles in the Code and Regulations, No. 551, examines the history of §482 and the regulations thereunder, explores the relationship between §482 and general federal income tax principles and doctrines, and analyzes the general principles in the Code and regulations dealing with §482.

This Portfolio is a companion to 552 T.M., Section 482 Allocations: Specific Allocation Methods and Rules in the Code and Regulations, and 553 T.M., Section 482 Allocations: Judicial Decisions and IRS Practice.

This Portfolio may be cited as Lepard, 551 T.M., Section 482 Allocations: General Principles in the Code and Regulations.

Table of Contents

I. Introduction
II. A Brief History of §482
III. A Brief History of the Regulations Under §482
IV. The Statutory and Regulatory Context for §482: An Overview of General Federal Income Tax Principles and Doctrines
V. The Use of Particular Allocation Methods in Other Provisions of the Code and Regulations
VI. Some Problems of Interpretation Under the Statute
VII. Interpreting the Arm’s-Length Standard in the Regulations
VIII. The Structure of the 1994 Regulations and the Best Method Rule