slides - NABE
slides - NABE
slides - NABE
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Conforming Adjustments A working definition: Following a primary allocation under §482, asecondary adjustment made to rationalize the actual transactionsbetween controlled parties. Treas. Reg. §1.482-1(g)(3). Default rule: a discrepancy between actual and arm’s-lengthtransaction results in deemed capital contribution or dividend, as thecase may be Election: taxpayers may elect to establish a payable/receivablepursuant to an applicable revenue procedure, currently Rev. Proc.99-32 The resulting payable/receivable can be satisfied without further U.S.tax consequences12