The foundation of international taxable income allocations between related parties is formed by the imposition of an arm's length standard. The presence of "control" over a person invokes this measure. The author examines the implications of control presented by continuing developments in the global business environment, including the rise of cooperative interfirm arrangements.
Wayne M. Gazur,
The Forgotten Link: "Control" in Section 482,
Nw. J. Int'l L. & Bus.