- 19 - 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 thePage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011