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QUESTION
USAco, a domestic corporation, sells widgets to its wholly-owned foreign subsidiary, FORco, for resale in country F. USAco charges FORco $17 for a...
USAco, a domestic corporation, sells widgets to its wholly-owned foreign subsidiary, FORco, for resale in country F. USAco charges FORco $17 for a widget that FORco resells for $21. The IRS makes a transfer pricing assessment, adjusting the price of a widget to what the IRS believes to be the arm's length price of $20. In response to this assessment, USAco can:
