...residents of a Contracting State, owned or controlled directly or indirectly by the same interests when necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such persons. ARTICLE 10 DIVIDENDS 1. Dividends paid by a company which is a resident of a Contracting State...

..."distribute, apportion, or allocate" income between or among organizations controlled by common interests in order to "prevent evasion of taxes or clearly to...reflect the income of any of such organizations." The effect of a proper application of section 482 is to place a controlled taxpayer on a parity with...

...apportion, or allocate gross income, deductions, credits, or allowances between or among such . . . businesses, if he determines that such distribution,...taxes or clearly to reflect the income of any of such . . . businesses."27 27 Cf. Treasury Department's Model Income Tax Treaty of June 16, 1981, Art. 9,...

...or among such commonlycontrolled organizations, trades, or businesses "in order to prevent evasion or clearly to reflect the income of any of such organizations, trades, or businesses. ■ The Service ' s administration of Code $ 482 has been eminently successful. Comprehensive regulations exist...

...one of the treaty countries, owned or controlled directly or indirectly by the same interests, where necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such persons. It is understood, however, that the United States is entitled under the proposed treaty to...

...residents of a treaty country, owned or controlled directly or indirectly by the same interests, when necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such persons. The distribution, apportionment, or allocation by the government of a treaty country of tax...

...the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses,...any of such organizations, trades, or businesses." resulted if the parties had been uncontrolled parties dealing at arm's length (Treas. Reg. sec. 1.482-l(bXD).49...

...the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades or businesses,...any of such organizations, trades, or businesses. (Emphasis added). The arm's-length method of the Code Section 482 regulations does not necessarily...

...the Treasury "to distribute, apportion, or allocate gross income or deductions between or among such trades or businesses, if he determines that such distribution,...taxes or clearly to reflect the income of any of such trades or businesses." Except for the "commensurate with income" standard added as part of the Tax...

...residents of a treaty country, owned or controlled directly or indirectly by the same interests, when necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such persons. The distribution, apportionment, or allocation by the tax authorities of a treaty country...