The Coca-Cola Company, and Includible Subsidiaries - Page 19

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          an independent sale price from comparable uncontrolled                      
          transactions, or if an independent sale price from comparable               
          uncontrolled transactions cannot be determined, then the sale               
          price is determined using a production cost ratio method.  This             
          first requirement is not at issue for purposes of the instant               
          motion;                                                                     
               (2) the possessions corporation must determine its costs               
          attributable to the possession product under section 1.861-8,               
          Income Tax Regs.;                                                           
               (3) the possessions corporation must determine its expenses            
          allocable and apportionable to the possession product under                 
          section 1.861-8, Income Tax Regs.;                                          
               (4) each member of the affiliated group must determine its             
          costs attributable to the possession product under section 1.861-           
          8, Income Tax Regs; and                                                     
               (5) each member of the affiliated group must determine its             
          expenses allocable and apportionable to the integrated product              
          under section 1.861-8, Income Tax Regs.                                     
               Finally, Q&A-12 requires that each affiliate apportion to              
          the possession product on the basis of the ratio of the                     
          production costs for the possession product to the total                    
          production costs for the integrated product, the expenses the               
          affiliate allocated and apportioned to the integrated product.              
               In our second example, the total production costs associated           
          with the integrated product equal 80 cents per unit, and the                




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