Extract to table

The taxpayer must have maintained contemporaneous documentation as described in Treasury Regulation Section 1

The documentation must be in existence when the return is filed for the relevant taxable year; post-filing documentation is insufficient to satisfy this requirement

In addition to the principal documents, the taxpayer must maintain background documents that support the principal documents

482-1(c) sets forth the "best method rule," which provides that the arm's-length result of a controlled transaction must be determined under the method that, given the facts and circumstances, provides the most reliable measure of an arm's-length result

The best method analysis is a facts-and-circumstances inquiry that must be conducted for each category of controlled transaction