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The IRS often makes adjustments when there are transfer pricing issues. Transfer pricing issues exist under which of the following circumstances?
a. A U.S.-based taxpayer sells tangible property to an affiliate that is subject to U.S. income tax.
b. A U.S.-based taxpayer shares costs with an affiliate that is not subject to U.S. income tax and does not file a consolidated income tax return with the U.S.-based taxpayer.
c. A U.S.-based taxpayer enters into a service contract with an affiliate that is subject to U.S. income tax and files a consolidated income tax return with the U.S.-based taxpayer.
d. A U.S.-based taxpayer leases intangible property from an affiliate that is subject to U.S. income tax.
Answer:B
Choice "b" is correct. Transfer pricing issues exist when a U.S.-based taxpayer shares costs with an affiliate that either (i) is not subject to the U.S. income tax or (ii) does not file a consolidated income tax return with the U.S.-based taxpayer.
Choice "a" is incorrect. Transfer pricing issues arise when a U.S.-based taxpayer transfers, sells, purchases, or leases tangible property or intangible property to or from an affiliate that either (i) is not subject to U.S. income tax; or (ii) does not file a consolidated income tax return with the U.S.-based taxpayer.
Choice "c" is incorrect. Transfer pricing issues arise when a U.S.-based taxpayer enters into loan agreements or service contracts with an affiliate that either (i) is not subject to U.S. income tax; or (ii) does not file a consolidated income tax return with the U.S.-based taxpayer.
Choice "d" is incorrect. Transfer pricing issues arise when a U.S.-based taxpayer transfers, sells, purchases, or leases tangible property or intangible property to or from an affiliate that either (i) is not subject to U.S. income tax; or (ii) does not file a consolidated income tax return with the U.S.-based taxpayer.