Extract to table

More specifically, the mechanism of overlap operates as follows: If PBI is required to pay a higher royalty rate (11

This standard is the touchstone against which all § 482 adjustments must be measured

The best method rule is relevant here because the IRS's simultaneous application of separate methods to the CSA and royalty transactions must yield results that are collectively consistent with arm's-length outcomes when viewed in the aggregate

482-1(g)(4) requires that when a § 482 allocation is made, conforming adjustments must be made to all affected tax items

The regulation recognizes that a § 482 allocation does not exist in a vacuum; it has ripple effects throughout the tax system that must be accounted for to produce a coherent result

Courts have recognized that when the IRS makes adjustments to multiple intercompany transactions between the same controlled parties, the adjustments must be internally consistent