Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / pre-filing-memorandum-irs-apma.docx
pre-filing-memorandum-irs-apma.docx
Parties
Harkness LLP
United States-Germany Inc
Dates
April 14, 2025
June 29, 2006
July 7, 2025
December 31, 2024
January 1, 2019
July 1, 2022
July 15, 2018
January 1, 2025
December 31, 2029
December 31, 2025
Amounts
€1,280.6
$1.39
€8.74
€2.62
€1.57
€1.42
$4.12
$3.38
$740
$542.2
Obligations
These provisions impose accuracy-related penalties on transfer pricing adjustments resulting from substantial or gross valuation misstatements, and set forth the documentation requirements that a taxpayer must satisfy to avoid such penalties (including the requirement to maintain contemporaneous transfer pricing documentation)