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Marvelous Irc Section 482 Transfer Pricing #1 Intellectual Property Transfer Pricing Under IRC Section 482 - Porto Capital | Restructuring, Startup, Tax Planning & CFO Services

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Marvelous Irc Section 482 Transfer Pricing #1 Intellectual Property Transfer Pricing Under IRC Section 482 - Porto Capital | Restructuring, Startup, Tax Planning & CFO Services

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Irc

IRC,
  • Internal Revenue Code.

  • Section

    sec•tion (sekshən),USA pronunciation n. 
    1. a part that is cut off or separated.
    2. a distinct part or subdivision of anything, as an object, country, community, class, or the like: the poor section of town; the left section of a drawer.
    3. a distinct part or subdivision of a writing, as of a newspaper, legal code, chapter, etc.: the financial section of a daily paper; section 2 of the bylaws.
    4. one of a number of parts that can be fitted together to make a whole: sections of a fishing rod.
    5. (in most of the U.S. west of Ohio) one of the 36 numbered subdivisions, each one square mile (2.59 sq. km or 640 acres), of a township.
    6. an act or instance of cutting;
      separation by cutting.
      • the making of an incision.
      • an incision.
    7. a thin slice of a tissue, mineral, or the like, as for microscopic examination.
    8. a representation of an object as it would appear if cut by a plane, showing its internal structure.
    9. [Mil.]
      • a small unit consisting of two or more squads.
      • Also called  staff section. any of the subdivisions of a staff.
      • a small tactical division in naval and air units.
      • a division of a sleeping car containing both an upper and a lower berth.
      • a length of trackage, roadbed, signal equipment, etc., maintained by one crew.
    10. any of two or more trains, buses, or the like, running on the same route and schedule at the same time, one right behind the other, and considered as one unit, as when a second is necessary to accommodate more passengers than the first can carry: On holidays the New York to Boston train runs in three sections.
    11. a segment of a naturally segmented fruit, as of an orange or grapefruit.
    12. a division of an orchestra or band containing all the instruments of one class: a rhythm section.
    13. [Bookbinding.]signature (def. 8).
    14. Also called  section mark. a mark used to indicate a subdivision of a book, chapter, or the like, or as a mark of reference to a footnote.
    15. [Theat.]one of a series of circuits for controlling certain lights, as footlights.
    16. shape (def. 12).

    v.t. 
    1. to cut or divide into sections.
    2. to cut through so as to present a section.
    3. to make an incision.

    Transfer

    trans•fer (v. trans fûr, transfər;n., adj. transfər),USA pronunciation v.,  -ferred, -fer•ring, n., adj. 
    v.t. 
    1. to convey or remove from one place, person, etc., to another: He transferred the package from one hand to the other.
    2. to cause to pass from one person to another, as thought, qualities, or power;
      transmit.
    3. [Law.]to make over the possession or control of: to transfer a title to land.
    4. to imprint, impress, or otherwise convey (a drawing, design, pattern, etc.) from one surface to another.

    v.i. 
    1. to remove oneself from one place to another: to transfer from the New York office to London.
    2. to withdraw from one school, college, or the like, and enter another: I transferred from Rutgers to Tulane.
    3. to be moved from one place to another: to transfer to overseas duty.
    4. to change by means of a transfer from one bus, train, or the like, to another.

    n. 
    1. a means or system of transferring.
    2. an act of transferring.
    3. the fact of being transferred.
    4. a point or place for transferring.
    5. a ticket entitling a passenger to continue a journey on another bus, train, or the like.
    6. a drawing, design, pattern, or the like, that is or may be transferred from one surface to another, usually by direct contact.
    7. a person who changes or is changed from one college, military unit, business department, etc., to another.
    8. [Law.]a conveyance, by sale, gift, or otherwise, of real or personal property, to another.
    9. [Finance.]the act of having the ownership of a stock or registered bond transferred.
    10. Also called transfer of training.[Psychol.]the positive or negative influence of prior learning on subsequent learning. Cf. generalization (def. 4).
    11. Also called language transfer. the application of native-language rules in attempted performance in a second language, in some cases resulting in deviations from target-language norms and in other cases facilitating second-language acquisition.

    adj. 
    1. of, pertaining to, or involving transfer payments.
    trans•fer a•ble, trans•ferra•ble, adj. 
    trans•fer′a•bil i•ty, n. 
    trans•fer rer, n. 

    Pricing

    price (prīs),USA pronunciation n., v.,  priced, pric•ing. 
    n. 
    1. the sum or amount of money or its equivalent for which anything is bought, sold, or offered for sale.
    2. a sum offered for the capture of a person alive or dead: The authorities put a price on his head.
    3. the sum of money, or other consideration, for which a person's support, consent, etc., may be obtained, esp. in cases involving sacrifice of integrity: They claimed that every politician has a price.
    4. that which must be given, done, or undergone in order to obtain a thing: He gained the victory, but at a heavy price.
    5. odds (def. 2).
    6. [Archaic.]value or worth.
    7. [Archaic.]great value or worth (usually prec. by of ).
    8. at any price, at any cost, no matter how great: Their orders were to capture the town at any price.
    9. beyond or  without price, of incalculable value;
      priceless: The crown jewels are beyond price.

    v.t. 
    1. to fix the price of.
    2. to ask or determine the price of: We spent the day pricing furniture at various stores.
    pricea•ble, adj. 

    Transfer

    trans•fer (v. trans fûr, transfər;n., adj. transfər),USA pronunciation v.,  -ferred, -fer•ring, n., adj. 
    v.t. 
    1. to convey or remove from one place, person, etc., to another: He transferred the package from one hand to the other.
    2. to cause to pass from one person to another, as thought, qualities, or power;
      transmit.
    3. [Law.]to make over the possession or control of: to transfer a title to land.
    4. to imprint, impress, or otherwise convey (a drawing, design, pattern, etc.) from one surface to another.

    v.i. 
    1. to remove oneself from one place to another: to transfer from the New York office to London.
    2. to withdraw from one school, college, or the like, and enter another: I transferred from Rutgers to Tulane.
    3. to be moved from one place to another: to transfer to overseas duty.
    4. to change by means of a transfer from one bus, train, or the like, to another.

    n. 
    1. a means or system of transferring.
    2. an act of transferring.
    3. the fact of being transferred.
    4. a point or place for transferring.
    5. a ticket entitling a passenger to continue a journey on another bus, train, or the like.
    6. a drawing, design, pattern, or the like, that is or may be transferred from one surface to another, usually by direct contact.
    7. a person who changes or is changed from one college, military unit, business department, etc., to another.
    8. [Law.]a conveyance, by sale, gift, or otherwise, of real or personal property, to another.
    9. [Finance.]the act of having the ownership of a stock or registered bond transferred.
    10. Also called transfer of training.[Psychol.]the positive or negative influence of prior learning on subsequent learning. Cf. generalization (def. 4).
    11. Also called language transfer. the application of native-language rules in attempted performance in a second language, in some cases resulting in deviations from target-language norms and in other cases facilitating second-language acquisition.

    adj. 
    1. of, pertaining to, or involving transfer payments.
    trans•fer a•ble, trans•ferra•ble, adj. 
    trans•fer′a•bil i•ty, n. 
    trans•fer rer, n. 

    Pricing

    price (prīs),USA pronunciation n., v.,  priced, pric•ing. 
    n. 
    1. the sum or amount of money or its equivalent for which anything is bought, sold, or offered for sale.
    2. a sum offered for the capture of a person alive or dead: The authorities put a price on his head.
    3. the sum of money, or other consideration, for which a person's support, consent, etc., may be obtained, esp. in cases involving sacrifice of integrity: They claimed that every politician has a price.
    4. that which must be given, done, or undergone in order to obtain a thing: He gained the victory, but at a heavy price.
    5. odds (def. 2).
    6. [Archaic.]value or worth.
    7. [Archaic.]great value or worth (usually prec. by of ).
    8. at any price, at any cost, no matter how great: Their orders were to capture the town at any price.
    9. beyond or  without price, of incalculable value;
      priceless: The crown jewels are beyond price.

    v.t. 
    1. to fix the price of.
    2. to ask or determine the price of: We spent the day pricing furniture at various stores.
    pricea•ble, adj. 

    Under

    un•der (undər),USA pronunciation prep. 
    1. beneath and covered by: under a table; under a tree.
    2. below the surface of: under water; under the skin.
    3. at a point or position lower or further down than: He was hit just under his eye.
    4. in the position or state of bearing, supporting, sustaining, enduring, etc.: to sink under a heavy load.
    5. beneath the heading or within the category of: Classify the books under "Fiction'' and "General.''
    6. as designated, indicated, or represented by: to register under a new name.
    7. below in degree, amount, etc.;
      less than: purchased under cost.
    8. below in rank;
      of less dignity, importance, or the like: A corporal is under a sergeant.
    9. subject to the authority, direction, or supervision of: a bureau functioning under the prime minister.
    10. subject to the instruction or advice of: to study the violin under Heifetz.
    11. subject to the influence, condition, force, etc., of: under these circumstances; born under the sign of Taurus.
    12. protected, controlled, or watched by: under guard.
    13. authorized, warranted, or attested by: under one's hand or seal.
    14. in accordance with: under the provisions of the law.
    15. during the rule, administration, or government of: new laws passed under President Reagan.
    16. in the state or process of: under repair; a matter under consideration.
    17. powered by the means indicated: under sail; under steam.
    18. under wraps. See  wrap (def. 16).

    adv. 
    1. below or beneath something: Go over the fence, not under.
    2. beneath the surface.
    3. in a lower place.
    4. in a lower degree, amount, etc.: selling blouses for $25 and under.
    5. in a subordinate position or condition.
    6. in or into subjection or submission.
    7. go under: 
      • to give in;
        succumb;
        yield: She tried desperately to fight off her drowsiness, but felt herself going under.
      • to fail in business: After 20 years on the same corner they finally went under.

    adj. 
    1. beneath or on the underside: the under threads of the embroidery.
    2. lower in position.
    3. lower in degree, amount, etc.
    4. lower in rank or condition.
    5. subject to the control, effect, etc., as of a person, drug, or force: The hypnotist had her subject under at once. The patient was under as soon as he breathed the anesthetic.

    IRC

    IRC,
  • Internal Revenue Code.

  • Section

    sec•tion (sekshən),USA pronunciation n. 
    1. a part that is cut off or separated.
    2. a distinct part or subdivision of anything, as an object, country, community, class, or the like: the poor section of town; the left section of a drawer.
    3. a distinct part or subdivision of a writing, as of a newspaper, legal code, chapter, etc.: the financial section of a daily paper; section 2 of the bylaws.
    4. one of a number of parts that can be fitted together to make a whole: sections of a fishing rod.
    5. (in most of the U.S. west of Ohio) one of the 36 numbered subdivisions, each one square mile (2.59 sq. km or 640 acres), of a township.
    6. an act or instance of cutting;
      separation by cutting.
      • the making of an incision.
      • an incision.
    7. a thin slice of a tissue, mineral, or the like, as for microscopic examination.
    8. a representation of an object as it would appear if cut by a plane, showing its internal structure.
    9. [Mil.]
      • a small unit consisting of two or more squads.
      • Also called  staff section. any of the subdivisions of a staff.
      • a small tactical division in naval and air units.
      • a division of a sleeping car containing both an upper and a lower berth.
      • a length of trackage, roadbed, signal equipment, etc., maintained by one crew.
    10. any of two or more trains, buses, or the like, running on the same route and schedule at the same time, one right behind the other, and considered as one unit, as when a second is necessary to accommodate more passengers than the first can carry: On holidays the New York to Boston train runs in three sections.
    11. a segment of a naturally segmented fruit, as of an orange or grapefruit.
    12. a division of an orchestra or band containing all the instruments of one class: a rhythm section.
    13. [Bookbinding.]signature (def. 8).
    14. Also called  section mark. a mark used to indicate a subdivision of a book, chapter, or the like, or as a mark of reference to a footnote.
    15. [Theat.]one of a series of circuits for controlling certain lights, as footlights.
    16. shape (def. 12).

    v.t. 
    1. to cut or divide into sections.
    2. to cut through so as to present a section.
    3. to make an incision.

    Capital

    cap•i•tal1  (kapi tl),USA pronunciation n. 
    1. the city or town that is the official seat of government in a country, state, etc.: Tokyo is the capital of Japan.
    2. a city regarded as being of special eminence in some field of activity: New York is the dance capital of the world.
    3. See  capital letter. 
    4. the wealth, whether in money or property, owned or employed in business by an individual, firm, corporation, etc.
    5. an accumulated stock of such wealth.
    6. any form of wealth employed or capable of being employed in the production of more wealth.
    7. [Accountableing.]
      • assets remaining after deduction of liabilities;
        the net worth of a business.
      • the ownership interest in a business.
    8. any source of profit, advantage, power, etc.;
      asset: His indefatigable drive is his greatest capital.
    9. capitalists as a group or class (distinguished from labor): High taxation has reduced the spending power of capital.

    adj. 
    1. pertaining to financial capital: capital stock.
    2. principal;
      highly important: This guide offers suggestions of capital interest to travelers.
    3. chief, esp. as being the official seat of government of a country, state, etc.: the capital city of France.
    4. excellent or first-rate: a capital hotel; a capital fellow.
    5. See  capital letter. 
    6. involving the loss of life: capital punishment.
    7. punishable by death: a capital crime; a capital offender.
    8. fatal;
      extremely serious: a capital error.
    capi•tal•ness, n. 

    Services

    serv•ice1  (sûrvis),USA pronunciation  n., adj., v.,  -iced, -ic•ing. 
    n. 
    1. an act of helpful activity;
      help;
      aid: to do someone a service.
    2. the supplying or supplier of utilities or commodities, as water, electricity, or gas, required or demanded by the public.
    3. the providing or a provider of accommodation and activities required by the public, as maintenance, repair, etc.: The manufacturer guarantees service and parts.
    4. the organized system of apparatus, appliances, employees, etc., for supplying some accommodation required by the public: a television repair service.
    5. the supplying or a supplier of public communication and transportation: telephone service; bus service.
    6. the performance of duties or the duties performed as or by a waiter or servant;
      occupation or employment as a waiter or servant.
    7. employment in any duties or work for a person, organization, government, etc.
    8. a department of public employment, an administrative division of a government, or the body of public servants in it: the diplomatic service.
    9. the duty or work of public servants.
    10. the serving of a sovereign, state, or government in some official capacity.
      • the armed forces: in the service.
      • a branch of the armed forces, as the army or navy: Which service were you in during the war?
    11. [Ordn.]the actions required in loading and firing a cannon: service of the piece.
    12. Often,  services. the performance of any duties or work for another;
      helpful or professional activity: medical services.
    13. something made or done by a commercial organization for the public benefit and without regard to direct profit: Certain books are published at a loss as a public service.
    14. Also called  divine service. public religious worship according to prescribed form and order.
    15. a ritual or form prescribed for public worship or for some particular occasion: the marriage service.
    16. the serving of God by obedience, piety, etc.: voluntary service.
    17. a musical setting of the sung portions of a liturgy.
    18. a set of dishes, utensils, etc., for general table use or for particular use: a tea service; service for eight.
    19. See  answering service. 
    20. the serving of a process or writ upon a person.
    21. tarred spun yarn or other small stuff for covering the exterior of a rope.
    22. (in tennis, badminton, handball, etc.)
      • the act or manner of putting the ball or shuttlecock into play;
        serve.
      • the ball or shuttlecock as put into play.
    23. the mating of a female animal with the male.
    24. at someone's service, ready to be of help or use to someone;
      at one's disposal: You will have an English-speaking guide at your service.
    25. be of service, to be helpful or useful: If we can be of service, do not hesitate to call.

    adj. 
    1. of service;
      useful.
    2. of, pertaining to, or used by servants, delivery people, etc., or in serving food: service stairs; the service pieces in a set of dishes.
    3. supplying aids or services rather than products or goods: Medicine is one of the service professions.
    4. supplying maintenance and repair: He operates a service center for electrical appliances.
    5. of, for, or pertaining to the armed forces of a country or one of them: a service academy.
    6. charged for providing service: a service fee of 15 percent on the restaurant check.
    7. providing, authorizing, or guaranteeing service: a service industry; a service contract.

    v.t. 
    1. to make fit for use;
      repair;
      restore to condition for service: to service an automobile.
    2. to supply with aid, information, or other incidental services.
    3. (of a male animal) to mate with (a female animal).
    4. [Finance.]to pay off (a debt) over a period of time, as by meeting periodic interest payments.

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