You are the Tax Director in a FORTUNE 500 company. There is a new CFO and he comes to your office and asks the following:
“I understand that there are ways to shift income between taxpayers using management fees and royalty payments. He further stated that it was his understanding that the same techniques could be used to minimize both state tax and international tax liabilities.”
- Please draft a double-spaced memo that is at least one full page responding to the questions posed by the CFO. Please mention transfer pricing and Code Section 482.