Internal Revenue Code Section 482:

Allocation of income and deductions among taxpayers
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Location in U.S. Code: Title 26A, Chapter 1E, Part III

Section 482. Allocation of income and deductions among taxpayers

In any case of two or more organizations, trades, or businesses
(whether or not incorporated, whether or not organized in the
United States, and whether or not affiliated) owned or controlled
directly or indirectly by the same interests, the Secretary may
distribute, apportion, or allocate gross income, deductions,
credits, or allowances between or among such organizations, trades,
or businesses, if he determines that such distribution,
apportionment, or allocation is necessary in order to prevent
evasion of taxes or clearly to reflect the income of any of such
organizations, trades, or businesses. In the case of any transfer
(or license) of intangible property (within the meaning of section
936(h)(3)(B)), the income with respect to such transfer or license
shall be commensurate with the income attributable to the

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